United States Regions April 1979
Environmental Protection 1201 Elm Street
Agency Dallas, TX 75270
Water
<>EPA Environmental Final
Impact Statement
Wastewater Treatment Facilities
Terrebonne Parish, Louisiana
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
FOR
HOIJMA-TERREBONNE
REGIONAL SEWERAGE FACILITIES
GRANT NO. C-22-0356-01-0
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 6
DALLAS, TEXAS
'APRIL 1979
APPROVED BY:
AOLENE HARRISO*
REGIONAL ADMINISTRATOR
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Due to the limited number of changes and modifications required by comments
received on the draft EIS, this final EIS contains only those pages that
have required revisions or additions, plus the comment letters received
on the draft statement with EPA's responses to those comments. The
draft and final EIS's in combination provide full analysis of the envi-
ronmental issues regarding EPA's proposal to award additional grants for
the detailed design and construction of Parish-wide wastewater treatment
facilities in Terrebonne Parish, Louisiana.
Note: Page numbers followed with the letter "R" denote revised pages.
Page numbers followed with the letters "A - Z" and "AA - II" denote
new pages.
a.
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EXECUTIVE SUMMARY
( ) Draft Environmental Impact Statement
(X) Final Environmental Impact Statement
Environmental Protection Agency
Region 6
Dallas, Texas
1. Name of Action
Administrative (X)
Legislative ( )
2. Background
On February 25, 1977 EPA, Region 6, issued a Negative Declaration on a
proposed project for a regional sewerage system for Terrebonne Parish.
This Negative Declaration covered expansion of both existing plants plus
217. miles of line work for the proposed collection system. Controversy
developed during the review of the Negative Declaration concerning poten-
tial primary and secondary impacts on wetlands, endangered species, and
archeological resources. After evaluating the issues expressed in op-
position to the initial Negative Declaration, EPA issued a Modified
Negative Declaration on June 20, 1977 which covered only that portion
of the project for upgrading of existing sewage treatment facilities
within the City of Houma including rehabilitation of existing collection
lines. As a result of this decision and in connection with the Modified
Negative Declaration, an EIS was prepared on the portions of the project
that are intended to serve the presently-unsewered population in the
outlying areas of the parish (i.e. the system of force mains and holding
basins, the gravity collection system, and expansion of the sewage
treatment plants).
3. Environmental Setting
Terrebonne Parish is located on the central Gulf
Coast of Louisiana in what was once a Mississippi River delta
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formation. Approximately 86 percent of the parish's area is
open water or wetland marsh. The average elevation of the
parish is 5 ft above mean sea level, with the higher ground
along the natural bayou ridges. Drainage is generally very
slow, in a north-to-south direction. In the southern parts of
the parish, winds and tide frequently override this pattern.
The major flood threat to the parish is from hurricane tidal
surges. A large number of local forced drainage projects are
presently proposed or being implemented to reduce flooding of
developed areas.
The marshes and estuaries support numerous shellfish,
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4. Water Quality Problems
Terrebonne Parish has a significant surface-water
quality problem, particularly south of the Gulf Intracoastal
Waterway (GIWW). None of the existing private and public
treatment facilities can consistently meet the required effluent
limitations, and over 37,000 persons are not presently sewered.
Much of the expected population increase will occur in the
unsewered areas.
Pollution problems in the parish are compounded by
the complex hydrology. Depending on tides and wind, flows can
be in any direction, or nonexistent, thus preventing rapid
dissipation of pollutants. Saltwater intrusion, caused primarily
by the dredging of navigation canals and oil field access
channels, is also a major problem.
High coliform bacteria concentrations resulting from
raw and inadequately-treated sewage discharges and storrawater
runoff also cause problems. About 40 percent of the parish's
oyster grounds have been closed because of coliform contamina-
tion. The City of Houma's water supply is also affected.
5. Alternatives Evaluated.
Alternate plans inyo.lved determining the optimum
number and siting of treatment plants and selecting the treatment
processes for a parish-wide system. Siting alternatives
considered involved combinations of 2, 3, 4, 5, and 6 treatment
plants at various locations. Process alternatives considered
included land application, trickling filters, conventional
activated sludge, physical-chemical systems, waste stabilization
ponds with dissolved-air flotation, and activated bio-filters.
Also evaluated were the "no action" plan and a project less than <^" _ i
parish-wide in scope.
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6. Environmental Impacts of EPA's Proposed Action to Award <^ 1
Additional Grants.
Based on the evaluations completed and documented in
the draft and final EIS's (i.e., the environmental impact
analysis; review and comment on the draft EIS; the public
hearing on the draft EIS; and comments from interested indi-
viduals) EPA, Region 6, proposes to award Step 2 and 3 grants
on the following recommended project for parish-wide sewage
treatment facilities in Terrebonne Parish, Louisiana.
The project consist of two plants - an activated bio-
filter plant north of the GIWW, and a pond-DAF plant south
of the GIWW. Other project components include:
a) Expanding the proposed North and South treatment
plants by 4 and 3 mgd, respectively, to handle
future growth in presently-unsewered areas.
b) Constructing 29 holding basins, two major pumping
stations, and about 128 miles of major force main
with diameters from 4 to 16 inches.
c) Constructing a gravity collection system, with 336
minor pump stations, 103 grinder pump stations, 156
miles of minor force mains, and 266 miles of gravity
collection sewers.
. d) Constructing a small package wastewater treatment
plant at Isle de Jean Charles.
The project will collect sewage and transport it to
a holding basin through the gravity sewers and minor force
mains. Sewage will then be pumped to the next holding basin
and on to a treatment plant through the major force mains.
The holding basins will function as flow-equalization ponds so
that the pumps can continuously pump the average flow, and not
need to be sized for peak flows.
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The following environmental Impacts are expected as a
result of awarding additional grants on the project as proposed.
Short-term impacts of the proposed project will
result from the extensive construction activities required.
Dredging required for bayou and wetland crossings will destroy
bottom organisms in the immediate construction zone and temporarily
increase turbidity and siltation. Sewer line construction
will destroy vegetation, and allow erosion, but the areas
should revegetate within one or two growing seasons, except
for the large trees. Disruptions to traffic and public safety
hazards will be significant, since much of the construction
will be along highway rights-of-way.
Long-term direct impacts of the proposed project
will occur in many areas. The overall parish water quality
will improve because of eliminating raw discharges from
the presently-unsewered areas. Coliform bacteria pollution
will be greatly reduced, perhaps allowing the re-opening of
some oyster grounds, and lowering dangers to public health.
Minor short-term adverse water quality impacts will occur
periodically throughout the project's life as a result of
localized discharges of pollutants due to force mains or
holding basin levees breaking, pump failures, or hurricanes
overtopping holding basins. About 30 acres will be permanently
taken by the project, but only a small portion will be wetlands.
Permanent adverse impacts on the biological environment will
be extremely small. No known endangered or threatened species
will be affected by the project. Mitigation measures will be
incorporated to ensure that no archaeological resources will
be adversely impacted as a condition to the Step 2 Grant.
The greatest direct long-term adverse impact of the
project will be economic. At 1978 price levels, over $71
million of Federal funds and $33 million of local money will
I
be required for the entire project.
Revised from Draft
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The project will also cause secondary impacts, most
of which are related to induced land use changes. A small
amount of development will be induced by the project, mostly
along higher ground adjacent to existing development. Because
of parish land use controls, limited access, poor drainage,
and flood hazards, very little of this induced development
will occur in wetlands. No large tracts of vacant developable
land will be served by the project, and much of any development
induced will take place in existing areas, thus providing
small increases in the efficiency of the distribution of
public utilities and services. No major additions to any
public utility distribution systems will be required. Property
values in newly-sewered areas will increase, but this will be
offset somewhat by the cost of the collection system.
7. Coordination of Draft EIS
Copies of the draft EIS were made available to
Federal, State and local interests for review and comment.
Comments were received from the following Federal and State
agencies:
Advisory Council on Historic Preservation
Federal Energy Regulatory Commission
U.S. Department of Agriculture - Soil Conservation Service
U.S. Department of Commerce - Assistant Secretary for
Science and Technology
U.S. Department of Commerce - National Ocean Survey
U.S. Department of Commerce - National Marine Fisheries
Service
U.S. Department of Defense - Army Corps of Engineers
U.S. Department of Energy
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U.S. Department of the Interior - Heritage Conservation and
Recreation Service
U.S. Department of the Interior - Office of the. Secretary
U.S. Department of Transportation - Federal High Administration
State of Louisiana - Executive Department
State of Louisiana - Department of Culture, Recreation and Tourism
State of Louisiana - Department of Natural Resources
State of Louisiana - Department of Transportation and Development
State of Louisiana - Department of Urban and Community Affairs
State of Louisiana - Department of Wildlife and Fisheries
State of Louisiana - Office of Science, Technology and Environmental
Policy
8. Public Hearing
A Public Hearing on the Draft EIS was held on February 6,
1979 at 7:00 p.m. in the Police Jury Meeting Room, Courthouse
Annex, Houma, Louisiana. M_Nptice of Availability" on the Draft .
EIS_was published in the Federal. Register dated January 2, 1979.
Revised from Draft
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4.4 Operation and Maintenance Considerations 92
4.5 Project Costs 92
4.6 Construction Schedule 95
IMPACTS OF THE PROPOSED PROJECT . 97
5.1 Geologic Impacts 97
5.1.1 Subsidence 97
5.1.2 Soils 97
5.1.3 Alteration of Land Forms 98
5.2 Impacts on Hydrology 98
5.2.1 Temporary Impacts During Construction 98
5.2.2 Impacts of System Operation 99
5.3 Air and Sound Quality Impacts 101
5.3.1 Short-Term Impacts During Construction 101
5.3.2 Long-Term Impacts During Operation 102
5.4 Impacts on the Biological Environment 103
5.4.1 Impacts on Vegetative Resources 103
5.4.2 Impacts on Invertebrates 104
5.4.3 Impacts on Vertebrates 106
5.4.4 Summary of Biological Impacts 108
5.5 Effects on Archaeological and Historic Sites 108
5.6 Socioeconomic Impacts 109
5.6.1 Short-Term Impacts During Construction 109
5.6.2 Direct Land Use Impacts 110
5.6.3 Secondary Land Use Impacts 111
5.6.4 Economic Impacts 116
5.7 Cumulative Impacts 119
5.7.1 Forced Drainage Projects 119
5.7.2 Navigation Canals 120
5.7.3 Summary of Cumulative Impacts 120
Revised from Draft
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The parish has no unusual noise problems at the present time.
2.4 BIOLOGICAL SETTING
This section describes the composition and ecological relation-
ships of the major groups of plants and animals in Terrebonne Parish.
2.4.1 Botanical Elements
2.4.1.1 Introduction. Most of the project construction will occur., along
high ground in the northern reaches of the parish and along the natural
levee ridges paralleling the major distributaries that drain the area.
These ridges support mainly non-wetland vegetation that grades into wet-
land types away from the bayous.
The plant communities can usually be related to physiographic
features, drainage patterns, and human encroachment. These communities
include bottomland hardwoods, cypress-tupelogum swamps, marshes (grading
from fresh to saline in a north-to-south direction), agricultural crops,
and cultivated landscape plants occurring in residential areas.
Vegetation on the ridges, in the swamps, and in the marshes
directly or indirectly provides habitat, shelter, and food for hundreds
of species, notable of which are fur-bearing animals, alligators, water-
fowl, deer, rabbits, squirrels, and doves. Shrimp, crabs, oysters, and
menhaden thrive in coastal waters enriched by detritus run-off from land
areas. As noted by Day, et al (Reference 23), conditions for developing
the greatest possible overall estuarine productivity appear to be present
in the Mississippi Delta region, of which Terrebonne Parish is a large
part.
2.4.1.2 Bottomland Hardwoods and Cypress - Tupelogum Swamps.
Approximately 111,000 acres or about 7.5 percent of Terrebonne Parish is
in bottomland hardwoods and cypress-tupelogum swamps, 90,000 acres of
which are classified as forested wetland (Louisiana State Planning Office,
1975). These two vegetative communities are well-known, and usually occur
adjacent to one another, with intergradation along the contact. The hard-
woods occupy the higher and better-drained soils of the natural levees.
The bottomland hardwoods are characterized by such species as live oak,
black willow, tallowtree, elms, persimmon, hackberry, swamp-privet, and
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23ft
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honeylocust. In the cypress-tupelogum swamps, typical vegetative
species include tupelogum, bald cypress, black willow, pumpkin ash,
bitter pecan, buttonbush, elderberry, palmetto, smartweeds, and
alligatorweed. Typical aquatic plant species are coontail, water-
lettuce, and pickerelweed.
2.4.1.3 Marshes. The Louisiana Coastal Marshes have been subdivided by
Chabreck (Reference 11) into four vegetative types (determined primarily
on salinity). The vegetative-type categories - saline, brackish, interme-
diate, and fresh - generally parallel the coast in an east-west direction.
The plant species designated as characteristic of those marsh areas are
listed in Chabreck (Reference 11). Phytoplankton to be expected in these
areas are listed in Whitehurst (Reference 107). The variety of species
found decreases to the south as the marshes grade from fresh to saline.
Approximately 539,000 acres, or 38 percent, of Terrebonne Parish (Louisiana
State Planning Office, 1975) is marsh. The extent of the four marsh types
is shown in Figure 8.
a. Fresh marshes. Fresh marshes are the most northerly-extending
of the marsh types, and are located mostly south of the Intracoastal Water-
way. They have an average salinity of 1 ppt and a salinity range of .09-4.54
ppt (Chabreck, Reference 11). Plant species most characteristic of the
fresh marshes include maidencane, spikerushes, bulltongue, umbrella pennywort,
and giant cutgrass.
b. Intermediate marshes. The intermediate marshes form a continuous
narrow zone (1 to 2.5 miles wide) extending across the parish between
the fresh and brackish marshes. The water salinity averages 4.68 ppt,
and ranges from 0.34-9.80 ppt (Chabreck, Reference 11). Common plants
in the intermediate marsh zones include wiregrass, bearded spangletop,
three-cornered grass, deerpea, maidencane, cattails, water hyssop,
southern naid, and pluchea.
c. Brackish marshes. Salinity in the brackish marshes is appar-
ently much influenced by tides, as indicated by the wide salinity range.
The average salinity is 7.6 ppt, with a range from 2.42-18.50 ppt (Chabreck,
Reference 11). The most important plant species are wiregrass, saltgrass,
three-cornered grass, deerpea, and oystergrass.
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d. Saline marshes. Saline marshes occupy the coast of Terrebonne
Parish, and extend more than ten miles inland in some places. Tidal fluc-
tuations cause frequent flooding and draining, and variable high salinity
levels. This marsh type has the least plant diversity of the marshes.
Plant species most common in the saline marsh are oystergrass, saltgrass,
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estimated to be 9,088 alligators occupying 811.5 square miles
of suitable habitat, an average of 11.2 individuals per square
mile of habitat.
In January, 1977, most populations of the American
alligator were reclassified from endangered to threatened
status. This status change affected approximately 75 percent
of the total alligator population, and included virtually all
coastal areas throughout Florida, Georgia, Louisiana, South
Carolina, and Texas. The remaining 25 percent of the popu-
lation is still endangered, and includes some in the inland
portions of Louisiana. The new status reflects the alligator's
positive response to the strict conservation techniques applied.
No commercial hunting is permitted, but they are now available
for scientific research if the state authorities are in agreement
(Endangered Species Technical Bulletin, 1977). The rapid
increase in both local and total numbers is very strong evidence
that food is very abundant in the alligator habitat.
•
2.4.3.3 Birds. About 320 species of birds occur in various
parts of Terrebonne Parish during the year (Lowery, Reference
58; Hebrard, unpublished data). These birds may be broadly
classified, according to their seasonal occurrence, as winter
residents, summer residents, permanent residents, and migratory
transients. Table 2 shows the number of species of birds that
occur in the major natural habitats of the parish (Hebrard,
unpublished data). Of the five endangered bird species that
might occur in Louisiana, only three are likely to occur in
Terrebonne Parish,; The brown pelican is present in very low <^ i
numbers in Terrebonne Parish.
a. Wading bird nesting colonies. In a 1976 survey
(Portnoy, et al., Reference 73), researchers of the Louisiana
Cooperative Wildlife Research Unit located 11 active breeding
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c. Peregrine Falcon. This species occurs in Louisiana
from September through May, but is not known to have nested in
the state in recent years (Lowery, Reference 58). The files
in the Museum of Zoology at L.S.U. revealed no records of
Peregrine Falcons in Terrebonne Parish. This undoubtedly
reflects the bird's general rarity, but probably also reflects
the lack of regular coverage of this part of the state by
ornithologists. There are fairly regular winter records of
Peregrine Falcon sightings in Cameron Parish and the Grand
Isle area, both popular birdwatching areas.
2.4.3.4 Mammals. Of the four major wetland types, swamp
forest, with 25 species, supports the greatest diversity of
mammals. The number of species declines towards the coast.
There are 14 species in fresh marsh, 11 in brackish marsh, and
8 in saline marsh. Undisturbed forested ridges of high ground
may support up to 32 species of mammals (Hebrard, unpublished
data). Whale populations occurring off the coast are protected
by the Marine Mammal Act of 1972. They will not be affected
by the proposed project. The Red Wolf (Canis rufus) has no
known population this far east in Louisiana.
Species of primary commercial importance are nutria,
muskrat, raccoon,, mink,, and otter. An estimated average of .
78,000 muskrat pelts and 125,000 nutria pelts are produced
each year from Hydrologic Unit V (figures are calculated from
catches of muskrat and nutria at Point au Chien Wildlife
Management Area). Palmisano (Reference 70) reported on the
relative abundance of these five species in saline through
fresh marshes in southeastern Louisiana, but was not able to
make estimates of abundance in swamp forest. He reported that
muskrat abundance was greatest in brackish marsh, while nutria
were found more frequently in fresh marsh. Raccoons were also
most abundant in fresh marsh, and mink and otter were equally
distributed between fresh and brackish marsh.
Revised from Draft
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parish-wide referendum held on November 12, 1977, the voters
defeated a general parish zoning-ordinance proposal by a
margin of about 1.6 to 1. Without such an ordinance, the
Parish has very limited ability to control or influence deve-
lopment patterns.
2.6.3 Projects by Others. There are a number of projects
at the national, state, and local levels which could interact
with the proposed sewerage treatment facilities.
2.6.3.1 Federal Projects. The U.S. Army Corps of Engineers
operates and maintains a number of inland navigation projects
within Terrebonne Parish, including the Gulf Intracoastal
Waterway, the Houma Navigation Canal, and Bayous Grand Caillou,
Petit Caillou, and Terrebonne. Some of the proposed sewers
are planned to cross these waterways, and coordination will be
required to insure that they do not interfere with maintenance
and dredging operations. All sewerage facility construction
in wetlands or navigable waters requires permits from the
Corps of Engineers.
2.6.3.2 State Projects. The State of Louisiana is presently
in the process of relocating U.S. Highway 90 north of Houma.
This project is expected to attract new residential and commer-
cial development, particularly at interchanges. The proposed
alignment for the relocated U.S. Highway 90 is shown on Figure
13.
2.6.3.3 Local Projects. Terrebonne Parish is currently
implementing a forced-drainage plan throughout much of the
developed area of the parish. This plan includes a total of
47 individual project areas, 14 of which have been constructed
and are presently in operation, draining a total area of
19,570 acres. Three more areas are either under construction
or soon to be started. These three projects will drain an
additional 15,448 acres.
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This program was originally delayed for some time
because of concern over the impact of the projects on the
wetlands of the parish. The program is now proceeding on a
project'by project basis with the understanding that the
drained area will extend only up to the wetland interface.
This will allow development and use of the slightly higher
ground which is frequently inundated because of the low relief
and poor drainage, but will have much less effect on those
lands which are lower and are officially considered to be
wetlands. While much of the area included in the forced
drainage projects consists of previously developed areas of
the parish, a considerable amount of land formerly too poorly-
drained for development will be made usable by the projects.
2.6.4 Employment
2.6.4.1 Present Employment. Employment characteristics of
Terrebonne Parish are shown in Table 9. Parish employment
showed substantial increases in all major occupational sectors
between 1972 and 1977. The ten largest employment categories
in the parish are shown in Table 10. As this table shows, the
extraction of petroleum products and the manufacture of ships
and equipment for this extraction piay a very major role in
. the parish economy. • • •
2.6.4.2 Outlook for Major Employment Sectors. This section
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COTVAU-BAVOU BLUB MO. I
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FIGURE 14
TERREBONNE PARISH PROPOSED
REGIONAL SEWERAGE PLAN
MANAGEMENT AREA
N
> MAJOH HIOHWAY
tutunu s«»ou
CANAL
• MRISM BOUNOARr
• HOtOINO BASIN
II PUMP StATIOM
A TnCATMEMT FACIUTT
— FORCeMAIN
OULF Of MEXICO
CO
(D
SOURCt: UUtntO FROM EmiRONMEHTU AUEUMEMT. HOUMA-TEHREBOMNC
KEOIONAl 8EWEBAOE MAM. O «I ENGINEERS. III!
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treatment facilities. Eliminating use of poorly-functioning septic tank
systems should also reduce existing odors.
5.3.2.3 Noise. Project operation is not expected to produce offensive
noise levels at any of the facilities. The treatment plants are not imme-
diately adjacent to any sensitive receptors, and during normal operation
do not produce noise levels above approximately 75 dbA. (The 75 dbA sound
level does not prevent conversation in normal tones even immediately at
the source.) Pumps will all be electrically powered and will be entirely
enclosed.
5.4 IMPACTS ON THE BIOLOGICAL ENVIRONMENT
5.4.1 Impacts on Vegetative Resources
Removal of vegetation is an unavoidable adverse impact of con-
struction. Assuming at maximum a 100-ft-wide construction zone along
the entire length of the gravity sewers, which includes the parallel in-
stallation of the major and minor force mains, up to 3,230 acres could
be disturbed by constructing the project. Most of this affected area
will be in unvegetated public roads and streets, but about 220 acres of
wetlands will be disturbed. Except for the larger trees, natural
revegetation will occur within one or two growing seasons in these wetland
areas.
Local aquatic vegetative systems will be slightly affected by
the siltation and turbidity resulting from erosion of trenches and plant
sites, and from the dredging required for bayou and wetlands crossings.
Temporary changes in local drainage patterns may also allow some minor
amount of saltwater intrusion before the trenchline is restored to its
original contours.
The total area to be permanently cleared or dredged for all
holding basins is approximately 24 acres, no more than 10 acres of which
are wetlands. Holding basins most likely to be located in wetland areas
are those toward the tips of the southern bayous. An effort will be made
in the Step II design process to locate these holding basins out of wetland
areas, but since most of the limited upland-areas have already been developed,
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there are few suitable alternative sites. The vegetation at these sites
will be destroyed, with no re-growth.
Plant communities permanently affected by pipeline installation
will primarily be the bottomland hardwood forest areas and cypress-tupelogum
swamps, where cutting of slow-growing woody species will occur along the
pipe route. Crossings of previously undisturbed bottomland forests or
cypress swamps are expected to extend approximately 95,100 ft, affecting
up to approximately 220 acres. Pre-project conditions will be naturally
re-established within several seasons, except for replacement of the larger
trees and for about 40 acres of permanent maintenance easements, which
must be kept clear enough for maintenance access. Typical species to be
affected in the bottomland forests are live oak, black willow, tallowtree,
elms, persimmon, hackberry, swamp-privet, and honeylocust. In the cypress-
tupelogum swamps, common species are tupelogum, bald cypress, black willow,
pumpkin ash, bitter pecan, button bush, elderberry, palmetto, smartweeds,
and alligatorweed. No threatened or endangered vegetative species is
expected to be impacted by the project.
5.4.2 Impacts on Invertebrates
5.4.2.1 General Comments on Invertebrates. Placing sewer lines along
the high ground bordering the major bayous, and within or near highway
rights-of-way, will fall within the area of greatest human habitation
and coaction. While these areas do support invertebrate communities,
the human influence is already an integral part of the system, and dis-
turbance of these grounds will only temporarily interrupt the status quo.
No endangered species is involved and no cardinal food chain organism
would be involved to the extent of breaking the trophic scheme. In none
of these areas, either high- or lowlands, will the dredging reveal any
stratum that .is likely to render the disturbed area inhospitable to
repopulation.
The proposed construction of the holding basins, force mains,
and collection lines, and the attendant erosion and siltation, can only
temporarily interrupt the invertebrate communities, and every opportunity
will be available for quick repopulation of the disturbed area by virtue
of the vast aquatic habitat and the fact that this habitat is not isolated
from the remainder of the Louisiana marsh.
Revised from Draft
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5.4.2.2 Oyster Production. The major immediate problem facing the oyster
industry in Terrebonne Parish is in the central zone, where encroachment
by untreated wastewater has been rapid, and promises to get worse. Opera-
tion of the proposed regional sewerage system would undoubtedly go far
toward correcting this immediate problem, and might improve fecal coliform
readings in the presently-closed oyster grounds to the point that they
might be reopened. This cannot be stated with certainty, however, because
of the limited water quality data and the area's extremely complex hydrology.
Construction of the project will have no effect on oyster grounds.
5.4.2.3 Shrimp Production. Shrimp, crabs, and finfish are mobile, forms
that are not as closely dependent on water quality in a specific area as
are sessile species like oysters. Shrimp can simply avoid regions of
low oxygen, etc. In addition, the physiology and food habits of shrimp
are unlike those of the oyster, so that concentration of pathogenic organ-
isms in shrimp or crab tissue is not generally a problem from the stand-
point of human consumption. In fact, it is possible that increased levels
of organic matter resulting from sewage pollution could, under certain
conditions, be favorable for shrimp production. For example, the Grass
shrimp (Paleomonetes pugio) has recently been shown to depend on nematodes
for a major part of its diet. Nematodes are most abundant in sediments
high in organic content. For these reasons, operation of the proposed
project is not expected to have any appreciable effect on the shrimp.
fishery in Terrebonne Parish.
Probably the greatest threat to present high levels of coastal
Louisiana fishery production in general, and to shrimp production in parti-
cular, is the loss of wetland area. To the minimal extent that the proposed
project induces growth in or occupies marsh areas, its construction will
cause a loss of shrimp habitat.
5.4.3 Impacts on Vertebrates
5.4.3.1. Fishes. There is little likelihood that either construction
r
or operation of the proposed sewage treatment system will directly have
significant adverse impacts on fish communities. The elimination of
numerous point sources of untreated sewage discharge throughout the cen-
tral and southern portions of the Parish should generally enhance water
quality, and thus benefit the parish fishery.
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5.4.3.2 Amphibians and Reptiles.
a. General Comments. There are no apparent negative effects to
any of the resident amphibians or reptiles from the proposed project.
In fact, other animal groups which constitute food sources for amphi-
bians and reptiles are likely to benefit from this project. It is
possible that the local populations of animals inhabiting the area
around the effluent discharge will increase because of the localized
enrichment. However, this will be balanced by a loss of nutrients at
those discharges eliminated by the project.
b. American Alligator. There are no studies that directly address
the influence of sewage effluent on alligator populations. It seems likely
that there will be very little, if any, direct negative or positive effects
of the operation of the sewage project on the alligator. Construction
activities associated with the proposed project could have minor adverse
impacts on alligators. The construction of sewer lines through marsh
areas could disturb active nest sites, and pipeline trenches left open
overnight could pose a hazard to alligators.
5.4.3.3 Birds.
a. General comments. Because of their highly mobile nature, most
bird species will probably not be affected by construction or operation
of the proposed sewerage system, particularly those facilities that parallel '
highways. Where pipelines cross wetlands, summer and permanent residents
could be adversely affected by project construction. These species generally
nest from April to July, and any nests directly in construction areas
would likely be destroyed. The Barred Owl, Great Horned Owl and Bald
Eagle nest in the winter months.
Holding ponds and treatment lagoons may be beneficial to some
bird species. Concentrations of herons, egrets and some ducks (e.g.,
Scaup) are sometimes attracted to such ponds, presumably because of con-
centrations of certain food items.
b. Wading bird nesting colonies. Neither of the two nesting colon-
ies discussed in Section 2.4.3.3 are near enough to the proposed sewerage
system to be adversely affected by primary construction impacts.
_ ^ , Revised from Draft
lub K
-------
c. Bald Eagle. Two of the nests described in Section 2.4.3.3 are
located near the interface of swamp fore,st and cleared land, but both
are at least 0.8 miles from the nearest proposed sewer lines, so that
they should not be negatively impacted by construction activities.
d. Peregrine Falcon. Adverse effects of construction or opera- -
tion of the proposed sewerage system on wintering populations of
Peregrine Falcons are extremely unlikely, since it is a wide-ranging
species, and is not known to inhabit the general area.
5.4.3.4 Mammals. Since four holding basins will likely be placed in
wetlands, the land so used (up to ten acres) will be removed from total
furbearer habitat. The levees that will be constructed around the holding
ponds may well be used by muskrats, nutria and other furbearers as burrowing
or nesting sites (see Lowery, 1974b).
5.4.4 Summary of Biological Impacts
About 30 acres of land will be permanently impacted by the project, <^» i
and less than 10 acres of this total required for holding basins will
be in wetlands. Additonal wetlands, up to 220 acres, will be tempo-
rarily impacted by collection line construction, and these areas will
be allowed to revegetate and regain pre-project conditions. These
losses, both temporary and permanent, to this biological resource
constitute an adverse impact because of the important value wetlands
provide to biological production and water quality. There will also
be some loss of common wildlife habitat and species due to expansion
at the plant sites and construction of collection lines. Although
many of the larger, more mobile species can be expected to relocate
to similar adjacent areas, local populations will ultimately be reduced
by an amount equal to the carrying capacity of the areas lost. In
conclusion, however, when these impacts are considered in relationship
to the vast amount of natural.habitat (primarily wetlands) and species
not affected by the project within the parish, the net primary effect
of the proposed project on the biological resources in Terrebonnne Parish
are assessed as very minimal.
5.5 EFFECTS ON ARCHAEOLOGICAL AND HISTORIC SITES
As a part of the EIS study, a Level I Archaeological Assessment
and Preliminary Field Survey was conducted in Terrebonne parish in the
spring of 1978. This report is contained in the Technical Support Document.
The purpose of this survey was to locate and evaluate all known historic
and prehistoric sites which might be affected by the proposed project.
Revised from Draft
"M
107 R
-------
The archaeological survey located twenty prehistoric and four
historic sites within the vicinity of the proposed project. In addition,
seven localities where sites had been previously reported were examined,
but no evidence of cultural activity was found. Of the twenty-four sites
located, twelve were deemed to be highly significant and in need of preser->
vation in some fashion, while two were found to require further testing,
as access to them was denied by the property owners.
108 R <^ ' Revised from Draft
-------
problem would be to serve these plants with regional sewerage facilities.
5.7 CUMULATIVE IMPACTS
The proposed regional sewerage plan is only one of several major
projects either underway or being planned that will have cumulative impacts
on wetlands in Terrebonne Parish. Maintaining and enlarging the navigation
canals, and constructing and operating additional forced-drainage areas
will have cumulative effects on the parish's wetland resources.
5.7.1 Forced Drainage Projects . ..
The implementation of the forced drainage program proposed for
the parish could have a major impact on the rate and location of development.
The availability of a large amount of well-drained, flood-free vacant
land provided with regional sewerage service could lead to significant
increases in development. Because of the difficulties and expense of
construction in poorly-drained areas of the parish, lack of adequate drain-
age comprises a much greater impediment to development than the lack of
sewerage facilities. Thus it is felt that the provision of drainage is
a much greater stimulus to development than the provision of only sewerage
service.
As originally proposed, the forced drainage projects were to ^^ i
have drained large areas of the parish presently classified as wetlands.
Because of the concerns about impacts on these wetlands, the proposed
forced drainage projects are being revised to drain only the higher ground
from the bayou ridges back to the wetland interface. If all future forced
drainage projects for which definite plans have not yet been prepared
are likewise limited in the amount of wetlands they will drain, impacts
of the forced drainage projects will be significantly reduced, as will
the potential cumulative effects of the drainage and sewerage projects.
Forced-drainage projects may increase the possibilities of sewer
line breakage by draining soils with high subsidence potential. Where
the soils exhibit a wide range of subsidence potential, differential settle-
ment initiated by the forced-drainage project could lead to breakage of
sewer lines.
Revised from Draft
119 R
-------
5.7.2 Navigation Canals
Dredging new navigation canals and expanding existing ones will
adversely affect the parish wetlands. .Besides the direct taking of wetlands
for canal right-of-way' and spoil areas, the canals increase fresh water
run-off and allow saltwater intrusion during periods of low rainfall and
high tides. The canals also cut off the area's natural hydrologic flow
patterns, depriving certain areas of fresh water flows. All these factors
combine to destroy or alter adjacent wetland areas and their resident
biological communities.
5.7.3 Summary of Cumulative Impacts
The combined effect of these three projects constitutes a signi-
ficant adverse impact on the wetland resources of Terrebonne Parish.
While the regional sewerage plan will directly ?and indirectly cause minor <^ ' \
impacts on wetlands, this effect will be extremely small when compared
to the primary impacts of the other two projects.
120 R
<^V i Revised from Draft
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6.2 COORDINATION OF THE EIS
A public hearing on the Draft EIS was held on February 6, 1979 <^ '
in Houma, Louisiana, and was attended by approximately 40 people. Every
statement made at the hearing expressed support for the proposed project.
Copies of the Draft EIS were distributed to Federal, State,
and local agencies and interested individuals for review and comment.
Comments received from these parties have been reviewed and incorporated
into the Final EIS where appropriate. Copies of all comments received
and EPA's responses to those comments are presented as follows:
Comments From Page
Advisory Council on Historic Preservation (1/22/1979) 123-B
Advisory Council on Historic Preservation (2/1/1979) 123-D
Federal Energy Regulatory Commission 123-F
U.S. Department of Agriculture - Soil Conservation Service 123-G
U.S. Department of Commerce - Assistant Secretary for 123-J
Science and Technology
U.S. Department of Commerce - National Ocean Survey 123-K
U.S. Department of Commerce - National Marine Fisheries 123-L
Service
U.S. Department of Defense - Army Corps of Engineers 123-0
U.S. Department of Energy 123-Q
U.S. Department of the Interior - Heritage Conservation and 123-R
Recreation Service
U.S. Department of the Interior - Office of the Secretary 123-S
U.S. Department of Transportation - Federal High Administration 123-U
State of Louisiana - Executive Department 123-V
<^ • i Revised from Draft
123
-------
Comments From Page
State of Louisiana - Department of Culture, Recreation 123-X
and Tourism (12/22/1979)
State of Louisiana - Department of Culture, Recreation 123-Y
and Tourism (1/31/1979)
State of Louisiana - Department of Natural Resources 123-BE
State of Louisiana - Department of Transportation and 123-DD
Development
State of Louisiana - Department of Urban and Community 123-EE
Affairs
State of Louisiana - Department of Wildlife and Fisheries 123-FF
State of Louisiana - Office of Science, Technology and 123-11
Environmental Policy
123-A
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Advisorv
Council ^n
Historic
Preservation
1522 K Slreol NW.
VtbihlnRlan D.C.
20WI5
January 22, 1979
Mr. Clinton B. Spotts
Regional BIS Coordinator, Region 6
Environmental Protection Agency
1201 Elm Street
Dallas, Texas 752TO
Dear Mr. Spotts:
This Is to acknowledge receipt of the draft environmental
statement for the Wastevater Treatment Facilities, Terrebonne
Parish, Louisiana on December 20, 1978. We regret that we
will be unable to review and comment on this document In a
timely manner pursuant to Section 102(2)(C) of the National
Environmental Policy Act of 1969-
Nevertheless, the 'Environmental Protection Agency Is reminded
w that. If the proposed undertaking will affect properties
V Included In or eligible for inclusion in the National
"' Register of Historic Places, It Is required by Section 106
of the National Historic Preservation Act of 1966 (16 U.S.C.
Ii70f, as amended, 90 Stat. 1320) to afford the Council an
opportunity to comment on the undertaking prio.^ to the
approval of the expenditure of any Federal funds or prior to
the issuance of any license. The "Procedures for the
Protection of Historic and Cultural Properties" (36 CFH Part
' 800.d) detail the steps an agency la to follow in requesting
Council comment.
Generally, the Council considers environmental evaluations
to be adequate when they contain evidence of compliance with
Section 106 of the National Historic Preservation Act, as
amended. The environmental documentation must demonstrate
that either of the following conditions exists:
1. Do properties Included in or that may be eligible
for inclusion in the National Register of Historic
Places are located within the area of environmental
-------
K
Y
Page 2
Mr. Clinton B. Spotts
Terrebonne Parish
January 22, 1979
Impact, and the undertaking ulll not affect any euch
property. In making this determination, the Council
requires!
—eTldence that the agency has consulted the latest
edition of the Rational Register (Federal Register,
February T, 19T8, and Its monthly supplement9)|
—evidence of an effort to ensure the Identification of
properties eligible for Inclusion In the Rational
Register, Including evidence of contact vlth the State
Historic Preservation Officer, whose comments should be
Included In the final environmental statement.
2. Properties Included In or that nay be eligible for
Inclusion In the National Register are located within
the ares of environmental Impact, and the undertaking
vlll or will not affect any such property, tn cases
where there will be on effect, the final environmental
statement should contain evidence of compliance with
Section 106 of the National Historic Preservation Act
through the Council's "Procedures for the Protection of
Historic and Cultural Properties".
Should you have any questions, please call Michael C. Qulnn at
(303) aSb-lip&S, an FTS number.
Sincerely, j
touts S. Wall
Assistant Director
Office of Review and Compliance, Denver
EPA RESPONSE
As a condition to the Step 2 grant, mltlgntlon nramires to
alleviate adverse Impacts to archeolngtcsl resources, developed In
cooperation vlth the Louisiana Historical Preservation Officer, will
Include realignment of collection line* to avoid known sites located
and evaluated during the level I Survey. Additional measures Include
protection and Investigation prior to construct Ion and/or mnnltnrlni;
of construction activities hy a professional srchenlogtat. Should
any presently unknown cultural resources be discovered during con-
struction, work will be stopped and the properties will be evaluated
In consultation with the State Historical Preservation officer. The
Advisory Council on Historic Preservation will be afforded ilic op-
portunity to comment If any property Is subsequently determined
eligible for Inclusion to the National Register (pursuant to
Section BOO CFR !«>•
-------
Advisory
Council On
Historic
Preservation
IS22KSIieHNW.
VVishlngton [1C
20005
February 1, 1979
Mr. Clinton B. Spotts
Regional EIS Coordinator
Environmental Protection Agency
Region 6
1201 Elm Street
Dallas, Texas 7S270
Dear Hr. Spotts:
This is in response to your request of December 18, 1978,
for comments on the draft environmental statement (DES) for
the proposed Wastewater Treatment Facilities, Terrebonne
Parish, Louisiana. We have reviewed the DES and note that
the undertaking may affect Southdown Plantation, a property
included In the National Register of Historic Places, as well
as twenty-four archaeological sites that may be eligible for
Inclusion in the National Register.
Pursuant to Section 106 of the National Historic Preservation
Act of 1966 (16 U.S.C. Sec. 470f, as amended, 90 Stat.'1320)
Federal agencies must, prior to the approval of the expendi-
ture of any Federal funds or prior to the granting of any
license, permit, or other approval for an undertaking, afford
the Council an opportunity to comment on the effect of'the
undertaking upon properties Included in or eligible for
Inclusion In the National Register.
Until the requirements of Section 106 are met, the Council
considers the DES Incomplete In Its treatment of historical,
archaeological, architectural and cultural resources. To
remedy this deficiency, the Council will provide, in accord-
ance with Its "Procedures for the Protection of Historic and
Cultural Properties" (36 CFR Part 800), substantive comments
on the effect of the undertaking on these properties.
EPA RESPONSE
To alleviate any adverse Impacts to archeologlcal resources, the
Step 2 grant will Include a condition that collection lines be realigned
as necessary to avoid the sites located and evaluated In the Level I
Survey.
-------
Fage J
Hr. Clinton B. Spotta
Southdown Plantation
February 1. 1979
Mease call Mrs. Jane Kins at (303) J3«-«9«6, an FTS number.
to assist yon In completing this process.
Sincerely,
Louis 3. Vail
Chief. Western Office
Review and Compliance
-------
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, O.C. 20426
January 29, 1979
IN KKPIV ncrcit TOI
Mr. Clinton B. Spotts
Regional EIS Coordinator
Environmental Protection Agency, Region 6
1201 Elm Street
Dallas, Texas 75270
Dear Mr. Spotts:
I am replying to your request of December IS, 1978 to the
Federal Energy Regulatory Commission for comments on the Draft
Environmental Impact Statement for the Hastewater Treatment
Facilities In Terrebonne, Louisiana. This Draft EIS has been
reviewed by appropriate FERC Staff components upon whose
evaluation this response Is based.
The staff concentrates Its review of other agencies'
environmental Impact statements basically on those areas
of the electric power, natural gas, and oil pipeline Industries
for which the Commission has Jurisdiction by law, or where
staff has special expertise in evaluating environmental Impacts
involved with the proposed action. It does not appear that
there would be any significant Impacts In these areas of
concern nor serious conflicts with this agency's responsi-
bilities should this action be undertaken.
Thank you for the opportunity to review this statement.
Sincerely,
Jack H. lletneroann
Advisor on Environmental Quality
HO EPA RESPONSE NECESSARY
-------
February 3, 1979
K
I
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
Post Office Box 1630, Alexandria. La. M301
Dr. Clinton B. Spot Hi
Regional EIS Coordinator
EPA, Region 6
1201 Elm Street
Dallas, Texas 73270
Dear Mr. Spotts:
Re! Draft EIS For Wastewater Treatment Facilities, Terrebonne Pariah, La.
We appreciate the opportunity to revlev this draft CIS and offer these
comments.
The EIS points out on page V that 30 acres of land "111 be taken by the
project action. The statement also points out that some Impacts related
to Induced land use changes will occur. No detailed location maps of
these areaa to be committed to project uses were presented In the EIS.
Therefore, Identification could not be made of how much nf this land
would be prime or unique farmland. Tlie Irreveralble commitment of these
resources should be addressed.
The Soil Conservation Service recognizes that the National Environmental
Policy Act (HEPA) establishes • Federal policy to preserve Important
historic, cultural, and natural aspects of our national heritage and
mountains, wherever possible, an environment which supports diversity and
variety of Individual choice. This policy la understood to Include highly
productive farmlands. Prime farmlands are those whose value derives from
their general advantage as cropland due to aoll and water conditions.
Prljne farmland can be cropland, pastureland, forestland, or other land,
but not urban buildup land. Unique farmland Is land other than prime
farmland that la devoted to one of the following uses! sugarcane, citrus,
catfish ponds, or crawflah ponda.
Detailed aoll maps are published In the Soil Survey of Terrehonne Parish,
February 1960. Enclosed la a copy of this report, along with a list of
those aoll mapping units classified as prime farmland. An assessment
should be made of the Irreversible commitment of prime or unique farm-
land resulting from the project.
F.tA RF.SPONSF.
Or the 30 acres total that will be. permanently taken liy the
proposed project, at moat 13 acrea will br agricultural land. These
areaa, because of their aoll typea or the fact th.it thry are nerd primarily
for raising sugarcane, are considered to be prime or unique farmlandn.
It la recognized that the loss of the productive use of thene laitdn
represents an adverae Impact, and special effort wilt he made In the
Step II design proceaa to locate the proposed holding ha B Inn out of
these valuable areas. It mat be realized however, that hecausr of the
relatively limited amount nf higher ground available In the pariah,
there are very few non-wetland areas that are not either developed or
used for agricultural purposes.
-------
Clinton Spott3
-2-
Februory 5. 1979
The primary and secondary Impacts on erosion and water quality have been
addressed. The discussion of alternatives considered la well organized
and presented.
Sincerely,
Al ^_^
State Conservationist
Enclosure
cc: Director, Office of Federal Activities (Hall Code A-104)
Environmental Protection Agency
Room 537, M. Tower, 401 H. Street, S.H.
Washington, D.C. 20460
Director, Environmental Services
SCS, Washington, D.C.
Office of the Coordinator of Environmental Quality Activities
Office of the Secretary, USDA, Washington, D.C.
Administrator, USDA-SCS, Washington, D.C.
-------
Terrebonne Parish Prime Farmlands
Baldwin silly clay and stltjr clay loam
Commerce Milt loam, level phode
Commerce silt loamt nearly level phase
Commerce slltjr c!ny loan, level phase
Cypremort slit lo
-------
UNITED STATES DEPARTMENT OF COMMERCE
Tha Assistant Secretary lor Science and Technology
Waihington. D.C. 2O230 ••' • . . .
4335. "':-r' __
- •..'•• %..\ '*
>XN% • ..-.
January 31, 1979
Ms. Adlene Harrison
Regional Administration (6A)
U.S. Environmental Protection Agency
1201 Elm Street
Dallas, Texas 75270
Dear Ms. Harrison:
This is in reference to your draft environmental impact
statement entitled, "Wastewater Treatment Facilities
Terrebonne Parish, Louisiana." The enclosed comments
from the National Oceanic and Atmospheric Administration
are forwarded for your consideration.
Thank you for giving us an opportunity to provide these
comments, which we hope will be of assistance to you. We
would appreciate receiving eight (8) copies of the final
environmental impact statement.
Sincerely,
Sidney R'.
Deputy Assistant Secretary
for Environmental Affairs
Enclosures
Hemos f rom t
Hr. Gordon Lill
National Ocean Survey
Hr. Kenneth R. Roberts
National Marine Fisheries Service
NO EPA RESPONSE NECESSARY
-------
UNITED STATES DEPORTMENT Of COMMEPCE
IMntlonol Oceanic end Atmospheric Administration
OA/C52x6
J/tN 2 b 1979
..'..1 -. -. -,
TO: PP - Richard
7
FROM: OA/Cxt -
SUBJECT: DEIS 17812.31 - Hastewater Treatment Facilities.
Tervebonne Parish, Louisiana
The subject statement has been reviewed within the areas of NOS
responsibility and expertise, and In terms of the Impact of the
proposed action on NOS activities and projects.
The following comnent 1$ offered for your consideration.
Geodetic control survey monuments may be located In the proposed
project area. If there Is any planned activity which will disturb or
destroy these monuments, NOS requires not less than 90 days' notifica-
tion In advance of such activity In order to plan for their relocation.
NOS recommends that funding for this project Includes the cost of any
relocation required for NOS monuments.
P.rA RESPONSE
II it IB determined during detailed design of th* project (tint
any geodetic control survey monuments would be Impacted by construc-
tion, the Nut tonal Ocean Survey (NOS) will be notified at lenst 90
day* In advance to plan for their relocation. Coot of any relocation
required for NOS Konimentft la a grant eligible Item, relnbnraable hy PPA.
-------
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
tlAIIUNAL MmilME flSllfHIES StilVIT.i
Duval Building Ni
9450 Koger Boulevard
St. Petersburg, FL 33702
January, 24, 1979
TO: Richard L. Lehman, Acting iai: .> q In7n
Kit a-*???. ~/z>-rt
-------
Additionally, the U.S. Environmental Protection Agency. In their
statement on protection of the Nation's Wetlands originally
Issued In March, 1973 (38 Fit 10834. March 20, 1973), noted that
wetlands need to be preserved when siting waste water treatment
facilities. Moreover, we note that vegetated wetlands are
Important for water quality since they provide some secondary
and tertiary treatment of domestic sewage. (Gossellnk et al,
1974).
In view of the above, the final EIS should thoroughly discuss
the rationale for determining that the proposed wetland destruc-
tion is insignificant, especially In light of the cumulative
effects of many such water development projects that Impact
wetlands. Also, the sections on development In wetlands,
especially the holding basin locations, should be discussed In
more .detail In the FEIS. This discussion should Include the
acreage and type of wetlands Involved and the value of even
small units of wetlands to biological production and water
quality. He further suggest that the section on alternatives
be expanded to discuss the use of upland sites for the develop-
ment now proposed In wetland areas.
KI'A
As requested, the alternative to utlllre upland arena for holding
basins trait Investigated anil only four of HIP proponed 29 holding bnslns
will be located In wetland are**. In these cases, certain forlorn
preclude the uac of upland altea. Becaune of the extremely limited
amount of high ground along the southern bayous there are few, If any,
holding basin altea. Much of the higher land hns heen tnken for resi-
dential development, and use of adjacent areas for sewage holding
bnalna would create eerloiis social and aesthetic Impacts on neighboring
.resldenta. It la alao Important to note that the anticipated Imparta
• on thene wetlands will be minimized by adjusting the actual placement
of each holding basin during detailed design ao that as little of the
10 acres as possible will be permanently Impacted.
-------
LITERATURE CITED
Gosselink, J.G., E.P. Odum, and R.M. Pope. 1974.
The value of the tidal marsh. Cent. Wetland
Resources, LA State Univ. LSI) Sea Grant Publ.
LSU-SG-74-03 30 p.
Gucinskl, H. 1978. A note on the Relation of Size to
Ecological Value of Some Wetlands. Estuaries.
1(3) p. 151-156.
-------
DEPARTMENT Qt THE ARMY
CHILEANS Distinct, conn* or
7 February 1979
LMMOO-K
Mr. Clinton B. Spotts
Regional EIS Coordinator
EPA, Region 6
1201 Elm Street
Dallas. Texna 75270
Dear Mr. Spotts:
Reference Is made to your letter dated 18 December 1978 requesting
comments on the draft environmental Impact statement (EIS) lor the
Uastewater Treatment Facilities, Terrebonne Parish, Louisiana.
Tills draft F.1S lias been reviewed In accordance with the Applicable
provisions of Part 1503 of the Council on Environmental Quality
Implementation of Procedural Provisions, Title 40, Chapter V, published
In the Federal Register dated 29 November 1978.
The following comments are provided in response to your request:
a. Suggest inclusion of site specific general water quality data
which hns been omitted from this draft. Such normally provided dntrt Is
necessary for proper analysis nnd evaluation of predictable'impacts on
area water quality that can be attributable to thla proposed project.
b. Suggest that those aspects of the proposed project that are
substnntfvr to B Federal Wntcr Pollution Control Act Srrtlon 404b
evaluation be clearly dt-n If.nntcd nnd ndequntely d|HCURSt*d. Wit Me most
major points are Included, (hey are neither clearly designated nor
discussed.
c. Suggest that the discussion of the Forced Drainage Projects under
paragraph 5.7.1 be revlned to reflect any substantive changes In
evaluation of features that may arise from a Parish-sponsored rentudy
that is ongoing. The rcstudy Is understood to Include both the scope
and alternatives which have not, heretofore, been considered. The
reference to Item 74 and/or 26, Its sitpplanter. In the list of RICrTRF.NCF.S
EPA RESPONSE
EPA dors not bellevr that Inclusion of ultr specific w.itrr quality
d.ita In warranted al this tine. Cenrr.il w.itrr quality Improvements
will occur across the entire parish an a result of thr operation of
a parish-wide collection and treatment iiystrm. Because of thr.
complex hydrology In the parish and the difficulty In quantifying
specific water quality effects resulting from the elimination of
widely distributed mat functioning septic systems nnd direct raw
discharges, the collection of even .1 large amount of data on present
water quality would not allow thr analysis and prediction of Int.urr
w.itrr quality throughout the parish.
Detailed site specific water quality Impact* resulting from construc-
tion of thr proponed facilities would also be unobtainable since
thr actual alignments for sewer line work wilt not he finalized
until thr Step It design work In completed. If the Corps of Engineers
require* » routine Section 404 permit application and ne.Ratrs the
"nationwide" permit, thr. permit evaluation couM consider the
probable, effects of site specific discharges of fill material since
more detailed information would hr available during Step II design.
b. Where Section 404 Is applicable to sewer line construction, (Rpiinnrr
of thr permit should proceed under the "nationwide*' permit concept
for placement of dredged or fill material as backfill or bedding
t
for utility line crossings, provided I.here Is no change In pre-
constrtictlnn bottom contours. (Excess material would hr remnvrd lo
an upland disposal area.) Thr evaluation of thr proposed project
presented In the EIS reveals that there would he no adverse ImpartB
on Ihe specific environmental elements nut.Kited as possible condi-
tions to this procedure |42 CFR Part 323, 323.1 - 3 (h)|.
-------
LMNOD-K 7 February 1979
Hr. Clinton B. Spotts
will be affected. Inasmuch as neither document has been released (or
public review, pursuant to Corps of Engineers regulations or the
Council of Environmental Quality guidelines or procedural provisions.
d. Suggest that .the content of paragraph 5.6.3.3 be adequately
expanded to reflect the syncrglatic- effects of this proposal and the
proposed and completed subprojects of the Forced Drainage Project on
secondary developments. Development of updated sewerage treatment
facilities for the llouma-Terrebonne area IB not planned to maintain the
status quo of meeting existing sewerage needs, but also to satisfy
future demand as well. This connotes project-induced development and
would certainly complement the planned Forced Drainage Projects for the
parish.
If we can be of further assistance In this natter, please advise.
Sincerely yours,
C. J. NETTLES
Chief, Operationa Division
K
V
EPA lUiSFOHSE (cuiiUiHi'id)
Specific sewer line location information is not available during
Step I planning to adequately consider either selection of disposal
sites or possible degradation of water uses and the aquatic environ-
ment which are applicable to Section 404 (b). However, if a "nation-
wide" permit is not appropriate and a routine application fnr a 404
permit is required by the Corps of Engineers, this permit evalua-
tion could consider the probable effects of the proposed placement
of fill material for Section 404 (b) in accordance wltK Environmental
Protection Agency Guidelines (40 CFR 230, September 5, 1975) during
the Step II detailed design of the project and before actual construc-
tion.
Section 2.6.3 (page 55) and Section 5.7.1 (page 119) have been revised
to reflect the changes made in the pariah forced drainage projects.
The cumulative impacts of the proposed sewerage project and the
several completed and proposed forced drainagc.projerts are dis-
cussed in revised Secton 5.7.1. We agree that the proposed sewerage
facilities would certainly complement the planned forced drainage
projects, as discussed In Section 5.7.1. However, EPA does not agree
that the provision of collection and treatment capacity fnr reason-
able future growth necessarily connotes project-induced development.
Terrcbonne Parish has grown considerably in the past 15 years
without regional sewerage facilities, and
economic forces which have driven this growth will continue to act
on the parish regardless of what actions are taken to alleviate
sewerage problems.
-------
Department of Energy
P.O. Box 35220 ..,, _
2626 W. Mockingbird Lane «""» »
Dallas. Tx. 75235
Ms. Adlene Harrison
Regional Administrator
Environmental Protection Agency, Region VI
1201 Elm Street
Dallas, Texas 75270
Dear Hs. Harrison:
As requested, we have reviewed the draft Environmental Impact Statement
for Wastewater Treatment Facilities, Terreborme Parish, Louisiana and
have no coirments.
Sincerely,
/ <
yfxc—6. Oan Rambo
/ Regional Representative
cc: Bob Stern, Acting Director, Division of REPA Affairs
NO F.PA FrsroNSF, NECF.SSARV
-------
K
I
United States Department of the Interior.
HERITAGE CONSERVATION AND RECREATION SERVICE
INTERACBNCY ARCIIEOUMilCAL SERVICES-ATLANTA
H2415-IAS-A
1899 Photnll Doulevard
AlUnu. KttriU 30.119
.'•IN
379
Clinton B. Spotts
Regional E.I.S. Coordinator
Environmental Protection Agency
Region 6
1201 Elm Street
Dallas, Texas 75270
Dear Hr. Spotta:
We have reviewed the draft Environmental Impact Statement
concerning the Waatewater Treatment Facilities, Terrebonne
Parish, Louisiana.
Paragraphs 2.51 and S.I which deal specifically with Impact
on cultural resources adequately address the problem.
Implementation of the areheologlcal survey recommendations
In the step 2 grant will satisfy those conditions concerned with
the protection of the cultural resources of Louisiana. However,
full compliance with 36 CFR 800 should be accomplished prior to
the Initiation of any Investigations.
We appreciate the opportunity to review the Environmental Impact
Statement.
Sincerely
•L
Bennle C. Keel
Chief
EPA RESPONSE
Implementation of the recommendations of the Cultural
Resources Survey will be made a condition of the Step II grant.
-------
United SlnlcB Deportment, of the Interi
OFFICE UFTIIK SBCIIBTAnV
mmtiiwe.irRF.oioN
COST iirrici! tnit jnw
«itm
CR-7B/1Z75
Mr. Clinton B. Spoils
Rrp.lonal CIS Coordinator
r.nvlronmentnl Protection Agency
1701 Kin. Street
Milan, Texas 75770
Pear Mr. Spottni
.•
Ve have revI rued the drift environmental Impact statement fop Vastewater
Treatment facilities, Terrebonne Parish, Louisiana, and offer the follow-
ing comments.
General Comments
We find that I lie Btatement Is deficient In providing adequate biological
Information, the statement could be substantially Improved with the
addition of wore site-specific Information on th» flora and fauna to be
affected by the project.
Terrebonne Parish, nn oroa of deltaic sediments w|tb]n the Hlsnlsslpplan
Pell.nlc Plain, has yielded more than IS percent of the State's mineral
values In recent years and also has had the second highest value for min-
eral production In lioulslana. The parish produces. In order of value,
petroleum, natural R.is, natural gas liquids, mil fur and salt. Although
dome lands will be removed from mineral exploration and possible produc-
tion when the treatment facilities, plpellnest etc., for the waslewater
system are built, the overall Impact on the mineral Industry should not
be significant. Proper well spacing, directional drilling, and other
environment-ally sensitive exploration and production drilling practices
cnittd offset or mlnimlr.e any such Impacts.
The statement properly Indicates the anticipated beneficial Impacts from
reduction lu lite une of septic tanlcs AIM! Inadequate small treatment
pl'tnts. However, because much of the proponed system would be In areas
of potable and useful ground water (nee figures S and 1*O, It should also
.ittdrrsR mitigation of ground water Impacts from sewer exllltratlon and
from lioldlng-tuisin leakage.
There Is no rllncun.ilon In the statement of whether the project will have
any Impact nn rrrrivitlon.il resources In the area. This should be clar-
ified lu the final ntatemeut.
r.r/i
Additional Mntogteftl Infornnt Ion vnn Included In Section 2.4,
Botnnleal Klemento, pnges 2), ?*, "nd 7P. More site nperlllc ltifnt«i-
t Ion on the flnr* and fnnnii to be affected by the |irn.|ert *mn Included
In Section 5.4, Impacts on the Biological Fnvl moment, pnp.on |nV|nr.
Conrnr. Since only four flrres at most wilt he rrtfiilrrd nt »ny
one project site, modern rxnlarnt Ion and prodtitt Inn 1rrhul<|iirs shtinld
made miy Impurt on the parish's mineral repourres nr
Figure 5 nhowv t.hnt only In the extirmr nnrl.hrrn nnd Rnntltern
sections of the pnrltih do mippllrn nf pnt.tble w»ter exist. Sli"-e these
supplies e»lBt »t depths of 200 to 100 leet below urn Irvel, lni|mrls In
l.he pnl»ble ground water rrglme Irnm sever exll It rut Ion nre rxpertrd t«
he negligible. All holding hanln.i will be lined In prrvrnt lc.tfc.i|>c.
The 0.1 arrr Folnte An r.hlrn hnldlnK b.ixln will be (minted rltbrr
InwdLitely ad|nce'nl to nr Jnnt Inside the liniind.ity of the Pnlnle An Chlrii
Vlldllfe Mnnngexent Area. There will also be a niri.ill length ol Inrre
m.iln In Hie itrcn, In he Incited entirely within highway r Ir.lil -«l -wny.
Aside Irnm this, there should br nn nflet-l nn r.perlllr tertr.it Inn l.i.tll-
tles. nrnrtnl rerrr.ttlnn.il flshlnp. In the p.irlnh shi.ntd br riili.ini ed.
-------
Specific Comments
Section 2 - Environmental Setting - This section should contain site-
specific biological data for each of the project's major construction
components. Description of the environmental setting at the proposed
North and South plants, the Isle de Jean Charles package plant, the
holding basin systems, and along the gravity pipeline system should be
Included.
Page 103, Paragraph 5.1.1 - The statement Indicates that project con-
struction will disturb about 220 acres of wetlands, and that this
dtstrtibance Is of minor adverse Impact. As this disturbance will actually
Include the destruction of some wetland acreage, these Impacts should not
be termed minor. Tills subsection should discuss the varying degree of
disturbance upon the 220 acres of wetlands. Wetland acreages which will
be permanently Impacted and those acreages which will only be temporarily
affected, should be shown for each major project element.
Page 109, Paragraph 5.5 - Documentation of the contact with the State
Historic Preservation Officer should be Included in any final statement.
Thank you for the opportunity to comment on this statement.
Sincerely,
V^A/^V—\S r[ *—/LAJ>-^_*-~^-
•lymond P. Cliuran
Regional Environmental Officer
Less than 10 acres of wetlands wilt b= permanently Impncted by
the project (I.e., required for lour holding basins) and an u wome
ciine condition Approximately 22O acres will suffer nlmrl-term Impact*
from construction of collection lines. Section 5.4.1, pnges 101-107,
was revised to Indicate the varying degree* of disturbances as requested.
Documentation of the conrdln.it Ion with I IIP Louisiana stale
Historic Preservation Officer is presented on page 123-V.
-------
U.S. DEPARTMENT OF TRANSPORTATION
»ro*OM «t>
750 Florida Boulevard
Baton Rouge, Louisiana 70801
December 22, 1978
Mr. Clinton B. Spotts
Regional EIS Coordinator
U>S. Environmental Protection Agency
1201 Elm Street
Dallas, Texas 75270
Denr Mr. Spotts!
Reference Is made to Its. Adlene Harrison's letter of December IS, 1970,
transmitting a copy of the DEIS Cor the upgrading of existing waste-
water treatment facilities of Tertebonne Parish, Louisiana, and
requesting FIIWA review. The following comments are offered for your
consideration !
1. It appears that a major portion of the force main syaten will
be located on Louisiana DOTD highway rlght-of'way. The DEIS makes no
reference to any coordination or consultation vtth then. Since the
DOTD will have to Issue penults for any work done on their right-of-way,
It Is recommended that they be provided an opportunity to review and
comment on the DEIS.
2. The Installation of the various force and gravity lines will
have a substantial Impact on the safe and efficient operation of the
area's roads and highways during construction. Some mention of the
mitigation measures that will be used to protect the motoring public
should be noted.
Sincerely yours,
i&JC^^T
ff' rTT"c. Relnhardt
f Division Administrator
KPA RESPONSE
The Louisiana Department of Transportation anil Development (LA
DOTD) was contacted and provided with a copy of the Draft EIS. Prrmltii
will be obtained from the LA DOTD for any work affrrtlnn 1,0111 n I ana Sl.-ile
highway facilities or rlghts-of-way.
All safety Measures recommended hy the Agwrlran Annnrlnl Inn a\
State Highway Officials, such aa warning «l|.ns( flanhrra, llnemrn, nnd
temporary fencing will be Implemented aa nltlgntlon nenRiiren to protect
the motoring public.
-------
of Tfonuuann
CDWIM EOWA
OOVIMNOK
February 9, 1979
Mr. ClInton B. Spotts
Regional US Coordinator
U. S. Environmental Protection Agency
Region 6
1201 Elm Street
Dallas, Texas 75270
Dear Mr. Spotts: :
In response to the draft Environmental Impact Statement for llouma-
Terrelionne Regional Sewerage Facilities, Grant No. C-220356-Ol, the
following coinnents are provided.
I Fully support the award by EPA of the cited grant, and the
commencement oF the regional sewerage facilities as expcditlously as
possible.
The project Is urgently needed For protection of the health of the
residents of Terrebonnc Parish, and to protect the quality and
productivity of the wetlands, which are extremely important to the
people and the economy of the parish. The long delays v/hich have
been encountered by municipal and parish government in their attempts
to reduce pollution and protect the productivity of oyster hcds and
other wildlife and fisheries resources, have resulted in a perpetuation'
of those problems, and a rapid escalation of the costs oF the project.
IF, therefore, the people of llouma and Tcrrchonne Parish have remained
willing to contribute the many millions of dollars of local funding
required, in spite of long delays and escalating costs, I must commend
and support them.
In the face of well-documented Information as to the extent of the
public health and water quality problems lhat the proposed project .is
designed to relieve, and the physical geography of Terrclionne Parish,
several objections to El'A's previous announcement of intent to Issue
a negative declaration on the project were raised. The draft E.I.S.
m.ikos It abundantly clear that the original judgment of your agency
was rational and well-founded, and that the objections wore trivial In
the light of the problems being addressed by the proposed project, and
the benefits of the project for protection of public health, water
quality, and wetlands productivity.
-------
Hr. Clinton 0. Snotts
February 9. 1979
Tage Two
I must observe that, although your agency's decision to enquire an E.I.S.
for a portion of the proposed project has onco annln demonstrated the
value of rapid action to Implement the grant award and complete the
project. It has also resulted In a delay and further cost Increases.
Therefore. I should like to suggest that In similar future circumstances,
where a small number of objections of a similar nature may be raised,
greater efforts be made to respond to' requests for Information prior to
making the decision to apply.the procedures of the national Environmental
Policy Act. In this case, and perhaps In future cases, It appears possible
that a thorough briefing of the groups who sought the provision of
additional Information by means of an E.I.S. might have hecn satisfied In
a more timely fashion, and that the resulting delays and cost Increases
might have been minimized.
I appreciate the opportunity you have provided for comment on the draft
E.I.S., and anticipate expeditious action to proceed with the award of the
grant sought by llouma and Terrebonne Parish.
Sincerely
EE:31p
e: The Louisiana Congressional Delegation
The Honorable Charles A. Duet, Sr.
President of the Terrebonne Parish Police Jury
Post Office Box 1035
llnuma, Louisiana 70361
The Honorable Edward P. "Biibba" Lyons
Mayor of the City of llouma
101 Jane
lloiimn, Louisiana 70360
F.PA
F.PA »|>rrrft fullj with your miKgrsI Ion lli.il In Hi« |.iln,r. •
•Ire IB I on r.lioul.l nr rrsrhrrl •( thi> enrllrnt pnr.M.lr I Imr , „,., :•,„!„, fir:
prrpnrol Ion. On future w.mt rwnlrr Irrntmrnt Cm-1 111 l-» pliimlng r.i ml
fiction* In l.onl • Imi.i vhrtr «n F.IS night lir rrrjnl tr.|, wr i»r m **lnr
Ihr "plRtytiarklnR" mrtlioil ol F.IS prrpnrnl Ion. thin ln.-..|vrr lit" |-,.-|.»,.
.linn of «n FIH * Imul t nnrnltnly with I hf prrpnrnt Ion of I lie futility ptnti.
IhtiB -cl Imlnat IIIR tfir nrrd for nn rnvl rniimrnlnl •nx*mnpt^|i.ii nf (t
, rommrnrrs nl Ilir nnssrl nf farllltlr* |.|»nolnr ni»1 I" t ••ir|. If I r,l |...|.,,,
thr fnclllllpn plnti In npprotrril l.jr (lir K(n|o nl,,t F.I'A.
Tlip "plMjr'"r'1" "Plh""! ol F.IS prrparnt Ion him (•r.-n pmvrn I..
lir flflrlrnt, tlnoljr, rrnpntinl vr In pul'llr p.irt lilp.il Ion nii'l rnv 11 ..n~-..i »
ronrrrim unit lis« riolncnl ilrl»jm anil roul InrrrniK-R In )>i.inl .ippl 11 .-oil i
On the avrr.iRr, nliont ? In 12 monthn run lir unvr-l iillllrlup ilil> »n>,...,, I,
It In our ilrnlrr In npplv thin mrlhml nf |m|>nrl xiinlynln In I lir nill.rl
.tilnptm nf 201 f.irllltr plnnnlnn, «"il vi- uoiilil .ipprrrlntr v nippml In
Hi Implrmriltnl Ion In l.nulBllila.
-------
EDWIN W. EDWARDS
GovKnof
STATE OF LOUISIANA
DEPARTMENT OF CULTURE, RECREATION AND TOURISM
OFFICE OF PROGRAM DEVELOPMENT
E. BERNARD CARRIER. PhD
AttJntfil S
J. LARRY CHAIN. PhO
Secretary
December 22, 1978
Mr. Clinton B. Spotts
Regional EIS Coordinator
EPA
1201 Elm Street
Dallas, Texas 75270
Dear Mr. Spotts:
Re: Draft Environmental Impact
Statement, Wastewater Treatment
Fact It ties, Terrebonne Parish,
Loutstana
Hy staff has reviewed the above referenced draft environmental Impact
statement. He have not received yet the cultural resources impact •/•/'••'•'
assessment conducted for this DEIS. He request that this assessment .
be sent to us as soon as possible so that we may initiate our review. ' '
If you have any questions; please contact my staff in the Division .f.-
of Archaeology and Historic Preservation at (504)342-6682.
Sincerely yours,
E. Bernard Carrier
State Historic Preservation Officer
EBC:CEP:mp
/'/•" /'*'.:
DIVISION OF ARCHAEOLOGY AND HISTORIC PRESERVATION
P. O. Bo« 44247 nnon n,n»|u Ll. >0n04 5O4 343 6607
NO EPA RESPONSE NECESSARY
-------
EDWIN w.
Rovwnor
STATE OF LOUISIANA
DEPARTMENT OF CULTURE. RECREATION AND TOURISM
OFFICE OF PROGRAM DEVELOPMENT
e. BEnnAno cAnnien. PM>
Allltllttt 3tct*t«rv
January Jl. |q/J
Hr. Clinton B. Spott5
Regional EIS Coordinator
Environmental Protection Agency, Region 6
1201 Elm Street
Dallas, Texas • 75270
RE: Cultural Resources Impact
Assessment, Iteuma-Terrebonne
Regional Sewerage Plan
Dear Mr. Spoils:
Hy staff has reviewed the above referenced cultural resources report by
Hr. Jeffrey H. Altschut of New World Research and offers the following
comments:
I. This report Is considered totally adequate as a level I survey. In
fact, the field work *nd report preparation can be considered an
excellent example of archaeological research, ff do not, however,
concur In full with Hr. Altschul's recommendations concerning the
significance of several of the sites located during the survey.
Archaeological sites may be considered eligible for Inclusion In
the National Register of Historic Places If they "have yielded, or
may be likely to yield. Information -Important to prehistory or history."
Generally, these properties must have maintained their Integrity to
the extent that they exhibit In situ and potentially Interprelable
cultural remains. The survey report (p.l9^( states that 5 sites
meet the criteria of eligibility for Inclusion In the National
Register. These are: I6trl9/j. l6TrJ7, ISTrJfl, !6Tr86, and ISLfJJ.
Cased on the data provided In the survey report, I suggest that four
additional sites meet the criteria of eligibility for Inclusion In
the Register. These sites are !6Tr7, ISTrJ), IfiTrSZ. and !6Tr9J
(Magnolia Plantation).
/
All of these sites display evidence of Intact and potentially Interpretable.
cultural material. In the case of the prehistoric sites this Is In the
form of mounds or midden material. At IfTrJJ, the Hagnolla Plantation,
this Is In the form of historic plantation home. The prehistoric sites
are considered significant In that they can yield Information concerning
a variety of aspects of prehistoric adaptations In the area. Additionally,
these sites can provide data on the complex geomorphology of southern
Lou IsI ana.
DIVISION Of ARCHAEOLOGY ANU HISTORIC PHSSEIIVATION
P. O. Bn« 447*7 flucm tltnur. I «. HWIM SM 3« 6TO1J
HO EPA RF.SrONSK MF.CF.RSART
-------
Page Two
January }l. 1979
Two sites, !6Tr63 and !6Tr72, may be eligible for Inclusion In the
Register, however, the data provided Is Insufficient to make a
determinal Ion.
2. When plans for the sewer line rlghts-of-way have been finalized, a
Level II on-the-ground survey of construction areas will be required.
At that time a determination of effect will have to be made for. those
known sites considered eligible for Inclusion In the National Register,
as well as for any additional significant sites located during the
survey. I concur with Hr. Altschul's recommendation that, where
possible, avoidance of significant sites Is the preferred action.
The following comments are directed at the archaeological and anthropological
Interpretations presented In the report. These comments do not Inlplnge upon
the report's adequacy as a Level I survey or In terms of Its fulfillment of
contract expectations. Rather, these comments are given In consideration of
this office's commitment to the discipline of anthropology.
I. The term "culture" Is undefined. The report states that a "culture"
or several "cultures" may have coexisted In the survey area. Hr. Altschul
is dealing with the material manifestations of the behavior of a or
several prehistoric populations. It Is not demonstrated that this
population (s) represents a unified or whole social cultural entity, a
portion of such an entity or several such entitles. There are no reasons
given to support the assumption that the survey area constituted a pre-
hlstorlcally "confined region" associated with a bounded soclo-cultural
unit.
2. Based upon available data concerning late prehistoric settlement systems,
among the most logical Interpretations of the observed variability In
settlement types Is that they represent the range of types of settlements
occupied by the same population. This hypothesis Is only casually pursued
In the report.
3. There are several questions which may be raised concerning the report's
ceramic analysis, especially the serial Ion. The available ceramic
collections are small and there seems to be no reason to assume that the
collections from most sites are representative of the ceramic population
at those sites. The author (p. 179) points out the problems Inherent In
using small, possible unrepresentative collections In seriatlon, and then,
without justification, proceeds to use the available collections.
To use seriatlon as a chronological Indicator, one must select ceramic
variables which will vary predictable over time. There Is little data
available which would indicate that the three pottery types selected are
reliable temporal Indicators within the brief time span considered. It Is
also apparent that the similarity In the results of the Hefghan and the
Brainard-Robinson seriation techniques Is that they essentially deal with
the same ceramic Information. Tin: three pottery types used In thu Hnigli;m
-------
rv>
I
Page Three
January Jl , 1979
serlatlon technique- comprise 821 of the total ceramic collection used
In the Bralnard-Roblnson analysis. Since there Is little difference In
the Information content of the data used In the two analyses one would
expect little difference In their results. Although the results of the
two techniques support one another, they can not he considered supportive
of a proposed chronological arrangement.
4. Fauna! data are used to tentatively support hypotheses about seasonallty
and site function. The available fauna! collection Is simply too small
to meaningfully support these contentions. In addition to Its small size,
a difficulty with the faunal data and the Interpretations placed upon It
stem from this site (98?) and. In fact a substantial proportion H7t)
of the total faunal collection from all sites, comes from the dredge spoil.
The collection from the dredge can not be considered comparable with that
from the remainder of site lolfJJ or with those from other sites.
Therefore, Interpretations placed upon the faunal collection from this site
as It relates to other sites are seriously marred because of the non-
comparability of the collections due to preservation and collecting
condition.
The comments given are mainly related to what Is considered an Insufficient
or weak data base. Despite these comments, Mr. Altschul's report can be
considered an excellent example of field research .and one of the few reports
of this type which attempts anthropological Interpretations beyond site
descriptions and listings.
I would appreciate your sending another copy of this survey report to this
office to be placed In the Louisiana State library.
If you have any questions concerning this matter, please do not hesitate to
contact my staff In the Division of Archaeology and Historic Preservation
telephone number (;o4) JM-6682.
Sincerely.
t. Bernard Carrier
State Historic Preservation Officer
EBCtCEPiesa
-------
January 29, 1979
DEPARTMENT OF NATURAL RESOURCES
OFFICE OF FORESTRY
(LOUISIANA FORESTRY COMMISSION)
D.L. UtFATTrn
AftSBTAHT SGCneTJ
STATE roAES.1
Hr. Clinton B. Spotts
Regional EIS Coordinator
U. S. Environmental Protection Agency
Region 6
1201 Elm Street
Dallas, Texaa 75270
Re: Draft Environmental Impact Statement
Waatewater Treatment Facilities
Terrebonne Parish, Louisiana
Dear Sir:
We are In receipt of Mrs. Harrison's letter and attachments of December 18,
M 1978, In connection with the above captloned project, and the request for
vi coiments on same.
A detailed review of the subject document reveals that approximately 220-
260 acres of bottomland hardwoods and cypress-tupelo gum timber will be
cleared to provide Cor installation of this project.
We are certainly in favor of wastewater and sewage treatment, and main-
tenance of the public health parameters which are dependent upon such
treatment.
At the same time, any timber which must be removed, and is, in fact,
merchantable, should be liquidated prior to construction by commercial
sale for the highest product and price possible, rather than by piling'
and burning, which Is a wasteful practice. This should be made a condition
of project approval.
In addition, great care should be exercised during construction to avoid
long-term or permanent interruption or alteration of surface and internal
drainage patterns and water regimes, to the extent that stresses are Intro-
duced which may result In degradation and deterioration of adjacent wet-
lands and downstream plant communities.
P.O. BOX IUM . MAT"N HOIICSE. LA. 7M3I
EPA RESPONSE
The estimate that approximately 220 acres of bottomland hard-
woods and cypress-tupelogun will be cleared in construction of the
proposed project was based on an assumed construction right-of-way width
of 100 feet over a length of about 18 miles. In these wetland areas,
both economic and ecologic factors will dictate a minimization of the
amount of wetland actually cleared. It is therefore likely that consider-
ably less than 220 acres of bottomland hardwoods and cypress-tupelogum
will actually be affected by construction of the proposed sewer lines.
All merchantable timber which roust be cleared will be made
available for public sale whenever economically feasible.
Backfilling of all sewer line trenches will be performed with
care to insure that no permanent changes are made to surface drainage
patterns.
-------
Mr. Clinton B. Spotta
January 29, 1979
Page 2
If the concerns expressed herein are properly addressed, 1 would have
no further comments on or objections to the project as outlined.
We would be happy to provide on the (round assistance In any ares of our
expertise, and to secure same those Involved should contact our local
district forester as follows!
E. George HI Her
District Forester
District 11
Office of forestry
Dept, of Natural Resources
302 Jefferson Street
Lafayette, La. 70502
Telephonet 264-5433
Thank you for the opportunity of reviewing this draft environmental Impact
statement.
VERNON E. ROBINSON - CHIEF, ENVIRONMENTAL RELATIONS
JW
cct District Forester Miller
-------
&lntr of louidinnn
Department of JErnnsporlnlion nub Qtbclopinrnt
EDWIN EOWAWDS
GovtPMon
Office of Public <5Uorh«
p. O. Vox 44155 Opnol ftiaon gbun Hongt. louiwiuu 70(0-1
January 31, 1979
Ms. Adlene Harrison
Regional Administrator (6A)
United States Environmental
Protection Agency
Region 6
1201 Elm Street
Dallas, Texas 75270
Dear Ms. Harrisoni
RE: Draft Environmental Impact
Statement, Hastewater Treatment
- Facilities, Terrebonne Parish
Reference is made to the draft environmental impact statement for
the above referenced proposed project enclosed with your
memorandum of December IB, 1978, which requested our review and
comments.
This is to advise that we have no comments to offer in regard to
this statement for this project at this time.
We appreciate the opportunity to review and comment on your, draft
environmental, impact statement.
cerely
ROY'
Assistant Secretary
RA/dmr
NO EPA RESPONSE NECESSARY
-------
Slate o( Louisiana
rDepaTljrtehrol'Urban and Community Affairs
- '•' ' Office
-------
ORLEANS 7OI3O
7 February 1979
CDWIN COWARDS
Mr. Clinton B. Spotts -
Regional EIS Coordinator
EPA, Region 6
1201 Elm Street
Dallas, Texas 75270
RE: Draft Environmental Impact Statement '
Wastewater Treatment Facilities
Terrebonne Parish
ru
V Dear Mr. Spotts: ' •
>3
Personnel of the Louisiana Department of Wildlife and Fisheries
have reviewed the above referenced project and offer the following com-
ments .
1.
2.
3.
Page 34, 2nd paragraph.
In Terrebonne Parish.
The brown pelican is not extinct
Page 37, Item 2. 4. 3. A. The Marine Mammal Act of 1972 pro-
tects some species occurring in this area.
Page 86, Figure. 14.) Ttlisi map should Include the location
of the Pointe Au Chien Wildlife Management Area (map en-
closed) . i
4. Every effort should be made to relocate, where possible,
proposed wetland portions of the project to nonwetland
areas . • '
5. All structures and/or construction activities on the
Pointe Au Chien Wildlife Management Area must be re-
viewed by the Refuge and Fur Division of this agency
foe possible conflicts with management plans.
1.
EPA RESPONSE
Concur. The brown pelican was at one time extinct in the parish,
but has since been re-introduced.
2. Concur. Page 37 has been revised.
3. Figure 14 has been revised to show the location of the Pointe An
Chien Wildlife Management Area.
4. Every effort will be made in the Step II design process to locale
project facilities in non-wetland area. In the southern sections
of the parish, the bayou ridges become increasingly narrow and the
amount of developable land is quite limited, with much of it being
devoted to residential use. Therefore, the amount of available non-
wetland ground suitable for sewerage facilities is quite limited.
5. The proposed Pointe Au Cbien holding basin will be located cither
just within or immediately adjacent to the Poinle Au Chien Wildlife
Management Area. Final location and design of the facility will be
coordinated with the Refuge and Fur Division of the Department of
Wildlife and Fisheries.
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S
-2-
Hr. Clinton B. Spottg
Draft EIS - Wastewater Treatment facilities - Terrebonne Parish
7 February 1979
6. Page 103. 2nd paragraph. The 100 foot wide construction
zone should be reduced to minimal area needed.
7. Page 103, 3rd paragraph. Saltwater Intrusion from
trench construction can be prevented by using modern
construction methods. Any saltwater Intrusion from
these activities should be reported to U. S. Fish and
Wildlife Service, landowner, sponsors of the project,
and this agency.
8. Page 104, 1st paragraph. Trees should be harvested,
not wlndrowed and Burned. Mitigation and/or compen-
sation for lost wetlands should also be clearly
stated. We suggest that you contact the U. S. Fish
and Wildlife Service In Lafayette during the early
stages of planning concerning any construction In
the wetlands.
. 9. All state and federal rulea and regulations are to
be followed.
10.,No untreated effluents from plants should be Intro-
duced Into St. Louis Canal or Terrebonne Bay or their
tributaries.
11. Use modern construction methods to reduce silt and
sediments during and after construction, especially
at the sewage plant site.
We appreciate the opportunity to review and comment on this pro-
ject during the early planning stapes.
Sincerely,
JBA:FOD:ms
cc: George Guilett
Len Leonard
J. 'Burton Angelle
Secretary
The assumption of a 100-foot wide cons)tnrtlon r.onr wins used In ntilpr
lo provide a conservative upper limit estlimite of the .urn to l>r
Impacted by rons.l ruction activities. In actual pracllrr, rcolnglr
and erononlr considerations will Unit this arra lo tin- minimum
necessary to efficiently carry out construction of the projrrt.
7. Concn r.
B. All merchantable timber which must be cleared will hr m.nle
available for public salr whenever economically feasible.
Coordlnntton with and comment* from the U*S« Department «»r
Interior, Including U.S. Fish nnd WUdllfe Service, are Inrluded on
pnp.pi, 123 5 nnd T.
9. Concur.
10. Ho bypassing of untreated effluents will be necessary.
II. Concur.
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"T*"-x- •• v , .IAS.' \, s iii~~ iT^<
POINTE AU CHIEN
WILDLIFE MANAGEMENT AREA
123-HH
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OFFICE OF SCIENCE. TECHNOLOGY i ENVIRONMENTAL POLICY
Edwin ff. Edwwrfa. Governor •
Lee ». Jrnnln». Muwlnt
January 3,
Mr. Clinton D. Spotts
Regional EIS Coordinator
EPA, Region VI
1201 Elm Street
Dallas, Texas 75270
RGt Houma-Terrebonne
Regional Sewerage Facilities
• Terrebonne Parish
Louisiana
Dear Mr. Spotts1
The above-referenced matter concerning environmental quality has
been received and reviewed by the staff of the Office of Science,
Technology and Environmental Policy. From the information contained
.in the package sent to our office, the staff of OSTGP issues a no
objection on this particular project. The rules and regulations
governing this project should continue to be in full compliance
with all State and Federal regulatory agencies.
The staff of OSTEP appreciates this opportunity to participate in
the review process.
Sincerely,
William J*. Hollere N
Manager, Administration and
Operations
WJM/cdh
ccs Mr. George Gullett, Environmental Coordinator
Office of Planning an'd Technical Assistance
Department of Urban and Community Affairs
HO EPA RF.RPONSF. NF.CF.SSAR?
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