United States
Environmental Protection
Agency
Region 4
345 Courtland street, Nt
Atlanta, GA 30308
AUGUST 1979
&EPA Environmental Final
Impact Statement
Greensboro-Guilford County,
North Carolina
Horsepen Creek Interceptor
EPA Project No. C370369-01
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FINAL ENVIRONMENTAL IMPACT STATEMENT
GREENSBORO-GUILFORD COUNTY, NORTH CAROLINA
HORSEPEN CREEK INTERCEPTOR
EPA PROJECT NO. C370369-01
Prepared by
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Approved
In cooperation with
the State of North Carolina
Department of Natural Resources
and
Community Development
Raleigh, North Carolina 27611
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TABLE OF CONTENTS
Page
Summary Sheet for Environmental Impact Statement iv
1.0 INTRODUCTION 1-1
2.0 ENVIRONMENTAL EVALUATION 2-1
2.1 Existing Environment 2-1
2.1.1 Natural Environment 2-1
2.1.2 Man-Made Environment 2-5
2.2 System Alternatives 2-7
2.3 Description of the Proposed Action 2-10
2.4 Environmental Effects of the Proposed
Action 2-15
2.4.1 Natural Environment 2-15
2.4.2 Man-Mage Environemnt 2-17
2.5 Mitigating Measures 2-18
3.0 REVISIONS TO THE DRAFT ENVIRONMENTAL IMPACT
STATEMENT 3-1
3.1 Wastewater Flows 3-1
3.1.1 Domestic and Commercial Flows 3-1
3.1.2 Industrial Flows 3-1
3.1.3 Institutional Flows 3-2
3.1.4 Other Flows 3-2
3.1.5 Summary 3-2
3.2 Collection Line Sizes 3-4
3.3 Cost Analysis of Alternatives 3-5
3.4 Errata 3-13
4.0 RESPONSES TO COMMENTS RECEIVED 4-1
4.1 Engineering Design 4-4
ii
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Page
4.2 Water/Air Quality Impacts 4-10
4.3 Economic and Human Resources Impacts 4-12
5.0 AGENCY DECISION . . 5-1
5.1 Conclusions 5-1
5.2 Step 2 Grant Conditions 5-3
6.0 BIBLIOGRAPHY 6-1
APPENDICES
Appendix A - Written Comments on the DEIS A-l
Appendix B - Transcripts of the DEIS Public
? Hearing B-l
iii
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SUMMARY SHEET FOR ENVIRONMENTAL IMPACT STATEMENT
Greensboro-Guilford County, North Carolina
Horsepen Creek Interceptor
Project No. C-37036901
Draft ( )
Final (X)
Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30308
1. Type of Action: Administrative Action (X)
Legislative ( )
2. Brief Description of Proposed Action:
This Environmental Impact Statement was prepared in response
to the proposed action of awarding grant funds to Guilford County,
North Carolina for the purpose of developing a wastewater treat-
ment system to service the Greensboro-Guilford County area of
which the Horsepen Cr^ek Interceptor is a part. The project con-
sists of the necessary facilities to transport wastewater from
the Horsepen Creek basin to the City of Greensboro wastewater
collection system for treatment. All of the Horsepen Creek
watershed and Lake Brandt, both of which are located entirely in
Guilford County, North Carolina, will be potentially affected by
the proposed action.
Physically, the proposed action consists of abandoning all
lift stations in the Horsepen Creek basin except the Albert Pick
lift station; construction of the Horsepen C.reek interceptor and
collectors running to the abandoned lift stations; construction
of a new lift station and force main near U.S. Highway 220 to
transfer Horsepen Creek interceptor wastewater to the North
Buffalo Creek (NBC) collection system, and construction of a
new force main from the Albert Pick lift station to transfer
Deep River tributary wastewater to a new outfall discharging
to the South Buffalo Creek (SBC) collection system. All lines
are sized to serve the existing population in the Horsepen Creek
basin.
The proposed action will provide for:
(1) the elimination of the present system of lift
stations and force mains in the area,
iv
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(2) a new collection system providing for transfer
of existing wastewater flows in Horsepen Creek
basin to the City of Greensboro wastewater
collection system, and
(3) sewering of areas with failing septic tanks.
3. Summary of Major Environmental Impacts
Direct adverse impacts associated with the proposed action
are minor. Construction of the interceptor system will cause
short-term, minor stream siltation and increased airborne par-
ticulates. Some natural vegetation will also be destroyed,
continuing a trend to habitat fragmentation. Certain individuals
will be subjected to temporary noise levels that exceed accept-
able thresholds. Low density development with widespread septic
tank use, as opposed to high density development with full sani-
tary sewerage, will be promoted. This will tend to lessen the
deleterious effects of urban runoff on Horsepen Creek and ulti-
mately on Lake Brandt. 1 Likewise, the proposed action will en-
courage adequate growth management planning measures be adopted
and current regulations be strictly enforced by local officials.
This is necessary to ensure that contamination of the City of
Greensboro's water supply in Lake Brandt does not occur as a
result of expected growth in the Horsepen Creek watershed.
Significant adverse secondary impacts include an unavoidable
lowering of water quality in Horsepen Creek due to urbanization.
These potential impacts would be much more severe under the future
service alternative than under the chosen action which limits
growth in the area to low density septic tank development. Land
use changes accompanying increased urbanization will virtually
eliminate farmland and forested areas in the basin, and reduced
sediment loads to Horsepen Creek may promote eutrophication in
Lake Brandt. Concentrations of pollutants in stormwater runoff,
especially lead, will increase as urbanization of the basin oc-
curs, which may result in unacceptably high levels of pollutants
in Lake Brandt. Arsenic levels may increase as well if its con-
centration in Lake Brandt is dependent on pH of inflowing waters.
Major beneficial impacts include elimination of the present
system of lift stations and force mains in the basin which have
occasionally surcharged in the past. Many poorly designed or
malfunctioning septic tank systems in current use will be eli-
minated. Finally, this project will promote the development of
planning measures for orderly urban growth in the Horsepen Creek
basin which are necessary to protect the City of Greensboro's
water supply in Lake Brandt.
v
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4. Summary of Alternatives Considered
The EIS process identified six (6) system alternatives for
this project. These alternatives were subjected to a multilevel
evaluation process (involving environmental, engineering, legal
and cost constraints) and inputs from the Greensboro-Horspen
Creek EIS Advisory Committee. Alternatives 1 through 4 can be
sized to serve either existing or future development.
Alternative 1 - abandon all lift stations in Horsepen Creek
basin except Albert Pick lift station; construction of Horsepen
Creek (HC) interceptor and collection lines to abandoned lift
stations; construction of new lift station and force main near
U.S. Highway 220 to transfer wastewater from HC interceptor to
North Buffalo Creek (NBC) collection system.
Alternative 2 - abandon all lift stations in HC basin except
Albert Pick lift station; construction of HC interceptor and col-
lection lines to abandoned lift stations; construction of a new
force main from Albert Pick lift station to new outfall discharg-
ing to South Buffalo Creek (SBC) collection system; construction
of new lift station and force main near U.S. Highway 220 to trans-
fer HC interceptor wastewater to NBC collection system.
Alternative 3 - abandon all lift stations in the HC basin ex-
cept Stage Coach Trail, Wagon Wheel, and Albert Pick lift sta-
tions; Stage Coach Trail lift station will transfer wastewater to
SBC collection system; construction of HC interceptor from Fleming
Road-New Garden Road intersection to U.S. Highway 220 and collec-
tion lines to abandoned lift stations; construction of new lift
station and force main near U.S. Highway 220 to transfer HC inter-
ceptor wastewater to NBC collection system.
Alternative 4 - abandon all lift stations ip. HC basin except
Stage Coach Trail, Wagon Wheel, and Albert Pick lift stations;
Stage Coach Trail lift station will transfer wastewater to SBC
collection system; construction of new force main from Albert
Pick lift station to new outfall discharging to SBC collection
system; construction of HC interceptor from Fleming Road-New
Garden Road intersection to U.S. Highway 220 and collection lines
to abandoned lift stations; construction of new lift station and
force main near U.S. Highway 220 to transfer HC interceptor waste-
water to NBC collection system.
Alternative 5 - No Action - maintain existing HC collection
system; new wastewater sources in excess of capacity must be ac-
commodated by septic tank systems.
Alternative 6 - Modified No Action - construction of new force
main from Albert Pick lift station to new outfall discharging to
SBC collection system; existing HC collection system will be main-
tained and operated with the addition of standby power.
vi
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5. Comments on the Draft Statement Were Received From the
Following:
Federal Agencies
Army Corps of Engineers
Department of the Interior
Department of Health, Education, and Welfare
Federal Energy Regulatory Agency
United States Department of Agriculture
State
North Carolina Division of Policy Development
Local
Superintendent of Schools: Guilford County
Mayor: Greensboro
Assistant Director of Public Works: Greensboro
Advisory Board for Environmental Quality: Guilford
County *
Commissioner: Guilford County
Chairman of the Board: Guilford County Commissioners
Guilford County Soil and Water Conservation District
Greensboro-High Point Airport Authority
Interested Groups
Audubon Society: T. Gilbert Pearson Chapter
Sierra Club: Joseph Le Conte Chapter
Environmental Action Coalition
Greensboro Chamber of Commerce
Board of Realtors
League of Women Voters
Greensboro-High Point Homebuilders Association
Individuals
Jack Jezorek
Mazie J. Levenson
R.H. Souther
6. Data Made Available to PER and the Public
The Final Environmental Impact Statement was made available
to OER and the Public in August 1979.
vii
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1.0 INTRODUCTION
This Final Environmental Impact Statement (FEIS) for
Greensboro-Guilford County, North Carolina, Horsepen Creek in-
terceptor supplements the Draft EIS (DEIS) issued in September,
1978. The FEIS has been prepared in accordance with the Council
on Environmental Quality (CEQ) Guidelines, at 40 CFR 1500, and
with EPA's 40 CFR 6 and requirements of the North Carolina Depart-
ment of Natural Resources and Community Development (DNRCD). The
FEIS fulfills the agencies' responsibilities under the National
Environmental Policy Act (PL 91-190) and the North Carolina
Environmental Policy Act of 1972 and EPA's regulations for en-
vironmental review Section 306 of construction grant applications.
While this summary document is intended to be comprehensive, the
supporting information furnished with the Draft EIS (RA-R-671)
should be reviewed and is incorporated here by reference.
This FEIS contains four major items of information.
The first is Chapter 2 which contains a summary of the detailed
environmental analysis conducted for the DEIS. The second item,
a description of the more significant recent revisions and addi-
tions to the information base on which the agencies' decision
was founded, is included as Chapter 3. (This chapter deals with
the substantive issues only, and is not intended to be a compila-
tion of corrections of typographical and other recognized minor
errors.) Chapter 4 presents the responses to public review and
comments on uhe DEIS. Copies of written communications and the
transcript of the public hearing are presented in Appendixes A
and B. Lastly Chapter 5 describes the final agency decision and
its rationale and includes the conditons required for Step 2 of
the construction grants process.
1-1
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In accordance with the regulations, a thirty-day re-
view and comment period will exist after publication of this
Final EIS and its filing with the OER. A conditional construc-
tion grant offer to Guilford County for funding Step 2 (detailed
engineering) of the proposed action described below is intended
after this public review period. Anyone receiving this document
who has not received a copy of the Draft may request one fromj
Mr. John E. Hagan, Chief
Environmental Impact Statement Branch
Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30308
1-2
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2.0 ENVIRONMENTAL EVALUATION
The detailed environmental analysis conducted for the
Draft EIS (RA-R-671) is summarized here to set the context for
the remainder of the Final EIS.
2 .1 Existing Environment
For the purposes of this Environmental Impact Statement
(EIS), the study area includes all of the Horsepen Creek basin,
as shown in Figure 2-1. The total environment is divided into
natural and man-made aspects and each, while interactive, is
discussed separately. Supporting documentation is provided in
a Technical Reference Document (RA-R-507) and the Greensboro
Draft EIS (EN-R-618).
2.1.1 Natural Environment
The Horsepen Creek basin area has a temperate climate
with short, mild winters and long, hot summers. Precipitation
is abundant.
Air pollutant emissions of the adjacent Greensboro area
are typical of a moderately industrialized urban region. The
general quality of the Greensboro area is good with respect to
criteria pollutants. Guilford County has been designated an
Air Quality Maintenance Area for suspended particulates.
Community-wide odor problems do not exist in the Horse-
pen Creek basin.
The noise climate of the study area is typical of simi-
lar suburban areas in the United States. Residential areas are
2-1
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ROCKINGHAM CO.
fO
l
to
Figure 2-1. Location of the Horsepen Creek Study Area
-------
characterized by low to moderate levels which, in most cases,
do not intrude upon outdoor activities. Higher noise levels
are present near major traffic arteries and the airport.
The topography of Guilford County is typical of the
Piedmont Plateau physiographic province in that it is gently rol-
ling in the uplands and somewhat more rugged near the major
streams. The bedrock of the county consists of igneous and
metamorphic rocks that are also typical of the Piedmont province.
The bedrock is overlain by a thick mantle of saprolite (soft,
weathered bedrock) in most of the county. The most important
geologic processes are ground-water recharge and flooding.
The soils of the Horsepen Creek basin are typical soils
of the piedmont uplands. Surface horizons are generally less
than one foot in thickness and are composed of brown or sandy
loam. Subsoils consist of red clay and are two to four feet in
thickness. The soils are mostly developed on deeply weathered
saprolite. Most of the Horsepen Creek soil series outside the
floodplain areas have phases that are considered prime farmland
soils. Nearly all of the soils in the study area are poorly
suited to septic tank use, primarily because of low permeability
in the subsoil horizon.
Horsepen Creek is the only stream in the study area.
The 7-day, 10-year low flow is less than 2 cubic feet per second
(cfs), and average flow is approxiamtely 17 cfs. Biological
oxygen demand (BOD) levels are low and dissolved oxygen (DO)
levels are high, indicating the current high water quality in
Horsepen Creek. Some problems exist with high fecal coliform
levels possibly due to septic tank contamination. The stream
is presently classified for drinking water use with a Class A-II
rating by the State of North Carolina. Horsepen Creek is a major
water supply for Lake Brandt, a municipal water use reservoir for
the City of Greensboro. Lake Brandt is considered moderately
eutrophic. High turbidity which limits light penetration is
2-3
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probably responsible for preventing the growth of aquatic macro-
phytes or nuisance algal blooms, since adequate nutrient concen-
trations for excessive growth of aquatic flora are present in
the lake. Preservation of Horsepen Creek water quality is widely
perceived as a necessity in order to protect the Greensboro water
supply in Lake Brandt.
Because of the geologic setting of Guilford County,
major regional aquifers do not exist. However, shallow, low-
productivity water-table aquifers are present and serve as im-
portant water sources in rural areas. The ground water of these
aquifers occurs in pore spaces in the saprolite and in fractures
in the underlying bedrodk. Recharge to the aquifers occurs in
the uplands, and discharge to wells or as baseflow to the
streams. The total ground water available in the county is esti-
mated to be about 150 MGD, but only approximately 11 MGD is pre-
sently being used. Ground-water quality is generally good, except
for a high iron content in some areas. Ground-water quality
problems from septic tanks have been reported in the county.
The potential natural vegetation in the Horsepen Creek
area is a climax hardwood forest. Man's use of the area has re-
sulted in the establishment of a mixed oak-hickory-pine forest
type which is now fragmented by cultivated fields, old fields,
and urban areas. No virgin woodlands remain. About 38 percent
of the total land in the study area is forested with second growth
woodlands in various stages of succession.
Because man's use of the study area has fragmented the
natural vegetation, forest species have decreased while species
preferring disturbed habitats have increased. Small game animals
and game birds have benefitted from fragmentation of the wood-
lands. Other game animals such as whitetail deer and wild turkey
2-4
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have been practically eliminated. Species tolerant of or espe-
cially adapted to man's alterations in natural conditions are
generally characteristic of the area's fauna.
Sport fishing is restricted to Lake Brandt in the study
area; habitat adequate for game fish in Horsepen Creek is probably
restricted to a few small pools. However, benthic invertebrates
are numerous and diverse in Horsepen Creek. The freshwater marsh
in the Lake Brandt headwaters represents a unique habitat in the
study area and is considered particularly sensitive to development
No virgin woodland stands remain in the study area.
Three plant species are listed as "threatened" throughout their
range in North Carolina. The southern rain orchid (Habenaria
flava), Nestronia (Nestronia umbellula), and ginseng are all
moist lowland species. None of the mammals of Guilford County
are considered endangered. The Bald Eagle once nested in the
area and the Peregrine Falcon migrates through the region. Both
are considered endangered by the U.S. Fish and Wildlife Service.
The sharp-shinned hawk is considered threatened and is reported
to nest near Lake Brandt. Species which are sensitive in the
area because they are relictual populations or occur at the edge
of their range include the white-crowned sparrow, crescent shiner,
and an unidentified species of freshwater clam.
2.1.2 Man-M.ade Environment
The Horsepen Creek study area had an estimated 13,830
people in 1979 and is projected to have 18,700 in 2000. The
land use pattern is a mixture of low-density suburban develop-
ment along the eastern boundary, commercial, and industrial in
the southwestern portion, and agricultural and forest land along
the western boundary.
2-5
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The Greensboro area economy has grown since 1970 with
20,000 jobs created in Guilford County from 1970 to 1974. Unem-
ployment has been low in recent years (normally under four per-
cent) . Manufacturing dominates the employment structure with
textile employment being conspicuously important. Employment in
manufacturing sectors such as wholesale/retail trade and services
has grown in recent years.
Greensboro and Guilford County are providing police
and fire protection, health care, education, waste disposal,
libraries, and other public services that are essential. Greens-
boro and Guilford County are financially sound governments, pay-
ing for their needs with: very little bonding required.
The Guilford County area has a rich cultural heritage
which is being enhanced and protected. National Register his-
toric sites are located in Greensboro and many buildings and
areas of historic value have been identified. Also, the area
may have archaeological resources, but they are not well known
at this time. Recreational resources are scattered throughout
the city and county.
As a focal point of North Carolina highways, Greensboro's
major thoroughfares are heavily used. Thoroughfares are planned
to relieve excess traffic loads as they develop, especially in
peripheral areas.
Duke Power Company will be able to meet the area's
energy requirements through the year 2000 as long as coal and
nuclear fuels are available. No major natural resources are.
being extracted in the study area.
2-6
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2.2
System Alternatives
All system alternatives were developed with the assump-
tion that an additional 4,870 people will move into the Horsepen
Creek basin over the next 20 years providing sanitary sewerage is
available. A total of six alternatives were considered, includ-
ing "No Action" and a "Modified No Action" scheme. These alter-
natives were tested in a multilevel screening process involving
environmental, engineering, legal and cost constraints, and
inputs from the Greensboro-Horsepen Creek EIS Advisory Committee.
A summary of these alternatives follows. Alternatives 1 through
4 can be siz-ed to serve either existing or future development.
Alternative 1 - abandon all lift stations in Horsepen
Creek basin except Albert Pick lift station; construction of
Horsepen Creek (HC) interceptor and collection lines to abandoned
lift stations; construction of new lift station and force main
near U.S. Highway 220 to transfer wastewater from HC interceptor
to North Buffalo Creek (NBC) collection system (see Figure 2-2).
Alternative 2 - abandon all lift stations in HC basin
except Albert Pick lift station; construction of HC interceptor
and collection lines to abandoned lift stations; construction of
a new force main from Albert Pick lift station to new outfall dis-
charging to South Buffalo Creek (SBC) collection system; con-
struction of new lift station and force main near U.S. Highway
220 to transfer HC interceptor wastewater to NBC collection sys-
tem, (see Figure 2-3).
2-7
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FORCE MAIN
FROM BRUSH
CREEK _0/£
TO NORTH
BUFFALO O/F
LEGEND:
¦ -
MAJOR ROAD
I II—
DRAINAGE BOUNDARY
_
SANITARY SEWER SERVICE AREA
¦
LIFT STATION
FORCE MAIN
fe-
GRAVITY SEWER
4000
SOUTH BUFFALO
BASIN
SCALE IN FEET
( LINE NO. \
v*—- ---+•)
DEEP RIVER
BASIN
Figure 2-2
ALTERNATIVE 1
-------
K>
I
vO
\
TO NORTH
BUFFALO O/F
LEGEND:
MAJOR ROAD
DRAINAGE BOUNDARY
—
SANITARY SEWER SERVICE AREA
¦
LIFT STATION
FORCE MAIN
-
GRAVITY SEWER
4000
SOUTH BUFFALO
BASIN
SCALE IN FEET
/ LINE NO. \
{• •*/
DEEP RIVER
BASIN
Figure 2-3
ALTERNATIVE 2
-------
Alternative 3 - abandon all lift stations in HC basin
except Stage Coach Trail, Wagon Wheel, and Albert Pick lift sta-
tion; Stage Coach Trail lift station will transfer wastewater to
SBC collection system; construction of HC interceptor from Flem-
ing Road-New Garden Road intersection to U.S. Highway 220 and
collection lines to abandoned lift stations; construction of new
lift station and force main near U.S. Highway 220 to transfer HC
interceptor wastewater to NBC collection system (see Figure 2-4).
Alternative 4 - abandon all lift stations in HC basin
except Stage Coach Trail, Wagon Wheel, and Albert Pick lift sta-
tions; Stage Coach Trail-lift station will transfer wastewater
to SBC collection system; construction of new force main from
Albert Pick lift station to new outfall discharging to SBC col-
lection system; construction of HC interceptor from Fleming Road-
New Garden Road intersection to U.S. Highway 220 and collection
lines to abandoned lift stations; construction of new lift sta-
tion and force main near U.S. Highway 220 to transfer HC inter-
ceptor wastewater to NBC collection system.(see Figure 2-5).
Alternative 5-"No Action" - maintain existing HC col-
lection system; new wastewater sources in excess of capacity
must be accommodated by septic tank systems (see Figure 2-6).
Alternative 6-"Modified No Action" - construction of
new force main from Albert Pick lift station to new outfall dis-
charging to SBC collection system; existing HC collection system
will be maintained and operated with the addition of standby
power (see Figure 2-7).
2.3 Description of the Proposed Action
The proposed action for wastewater collection system
improvements in the Horsepen Creek basin is Alternative 2E (which
is sized for existing development only) and is composed of:
2-10
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FORCE MAIN
FROM BRUSH
CREEK _0/£
TO NORTH
BUFFALO O/F
LEGEND:
MAJOR ROAD
DRAINAGE BOUNDARY
--
SANITARY SEWER SERVICE AREA
¦
LIFT STATION
FORCE MAIN
GRAVITY SEWER
4000
mmmj
SCALE IN FEET
^ LINE NO.,
Figure 2-4
DEEP RIVER
ALTERNATIVE 3
-------
to
I
K>
FORCE MAIN
FROM BRUSH
CREEK 0/£
TO NORTH
BUFFALO O/F
LEGEND:
MAJOR ROAD
¦i
DRAINAGE BOUNDARY
SANITARY SEWER SERVICE AREA
¦
LIFT STATION
FORCE MAIN
*.
GRAVITY SEWER
4000
SCALE IN FEET
LINE NO.
SOUTH BUFFALO
BASIN
DEEP RIVER
BASIN
Figure 2-5
ALTERNATIVE 4
-------
DEEP RIVER
BASIN
Figure 2-6
EXISTING FACILITIES
(NO ACTION, ALTERNATIVE 5)
-------
FORCE MrtN
FROM BR'.JSH
CREEK O/F
CARDINAL *2
,TO NORTH
BUFFALO OIF
\
TO NORTH
BUFFALO O/F
LEGEND:
——
MAJOR ROAD
DRAINAGE BOUNDARY
SANITARY SEWCR SERVICE AREA
¦
LIFT STATION
FORCE MAIN
*¦
GRAVITY SEWER
4000
DEEP RIVER
BASIN
SOUTH BUFFALO
BASIN
SCALE IN FEET
LINE NO. j
Figure 2-7
ALTERNATIVE 6
(MODIFIED NO ACTION)
-------
abandonment of all lift stations except
Albert Pick in HC basin,
construction of HC interceptor along the
creek and collection lines to abandoned
lift stations to provide service to exist-
ing developed areas,
construction of a new force main from the
Albert Pick lift station to transfer Deep
River tributary wastewater to a new outfall
discharging to the SBC collection system,
and
construction of a new lift station and force
main near U.S. Highway 220 to transfer HC
interceptor wastewater to the NBC wastewater
collection system.
2.4 Environmental Effects of the Proposed Action
2.4.1 Natural Environment
Direct air quality impacts of the proposed action will
occur during the construction phase. Only total suspended par-
ticulates (TSP) are of any concern. A short-term increase in
TSP levels from fugitive dust emissions may be expected to occur.
Indirect impacts associated with the predicted urbanization of
the Horsepen Creek area will be an elevation of ambient levels
of all the criteria air pollutants.
No adverse odor impacts are expected as a result of
the proposed action. A slight decrease in odor levels may occur
due to elimination of several lift stations that occasionally
surcharge.
2-15
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Noise levels in the area will increase during the con-
struction phase as a result of heavy equipment operation. Ambient
noise levels will increase gradually due to urbanization and at-
tendant increases in traffic, construction, etc.
No significant geological impacts are expected. Soil
will be lost due to erosion during construction of the intercep-
tor system. Urbanization of almost all prime farmland soils in
the area will be an indirect impact of this project. But this
land use change is expected to reduce soil loss due to erosion.
Ground-water supplies should not be affected appreciably
by this project. Total recharge in the area will be reduced
slightly due to the increases in impervious area expected as a
result of urbanization. "Ground-water quality should not be ad-
versely affected if good engineering practices are used to pre-
vent exfiltration from the proposed sewer system, and the capacity
of the lines is not exceeded. Existing septic tank problem areas
will be provided with sewer service. The possibility of future
septic tank problems should be alleviated by strict enforcement
of the new Guilford County septic tank ordinance.
The major direct impacts of the project on surface
water quality will be improvements in quality due to the sewer-
ing of existing septic tank problem areas and the elimination of
the system of lift stations. A short-term increase in sediment
loads during construction is the major adverse direct impact.
Indirect impacts are related to the predicted increase in non-
point source pollution due to urbanization of the Horsepen Creek
watershed. Ultimately, these impacts will be substantially less
under the proposed action than they would be if an alternative
serving future population were selected.
2-16
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BOD, phosphorus, and heavy metals concentration are
expected to increase in Horsepen Creek. Suspended solids and
dissolved oxygen levels are expected to decrease. These changes
in Horsepen Creek water quality will have an impact on Lake
Brandt water quality, as well. Reduced suspended solids levels
will lower turbidity in the lake, and this, in turn, may promote
eutrophication and the occurrence of nuisance algal blooms. Lead
and arsenic levels may increase as a result of urbanization, pre-
senting a potentially serious constraint to the use of Lake Brandt
water for drinking water purposes in Greensboro.
Direct impacts on the biological communities in the
Horsepen Creek basin as a result of this project will be minor.
Approximately 123 acres will be seriously disturbed during the
construction phase. Indirect impacts will be more significant
as urbanization occurs. The terrestrial habitats in the area
will become more fragmented, favoring those plants and animals
which are adapted to a closer¦association with man. The aquatic
habitat in Horsepen Creek may be impaired if nonpoint source
pollution increases. Any increase in pollutants will favor those
aquatic organisms which are adapted to their presence. A de-
crease in aquatic biota diversity can be expected.
2.4.2 Man-Made Environment
Most of the land now presently under cultivation or
forested will be converted to residential use under all project
alternatives. The pattern of development should follow estab-
lished trends with commercial and industrial development occur-
ring primarily in the southwestern portion of the basin. Future
subdivisions with sewers will probably occur adjacent to the
already sewered areas. The necessity of a low density septic
tank development in order to protect the Greensboro water supply
in Lake Brandt could result in a more costly public services system.
2-17
-------
Under any alternative for the provision of sewer service almost
all available land in the basin that is not environmentally
sensitive will eventually be developed. Development of sensitive
areas would have serious impacts and should be restricted.
2.5 Mitigating Measures
General mitigating measures regarding the direct im-
pacts of construction of an interceptor system on air quality,
noise, soils, etc., are addressed in the appropriate sections
in the Greensboro EIS (EN-R-618). Mitigating measures concern-
ing water quality and land use, those areas where significant
adverse impacts can be expected to occur, are summarized in the
following paragraphs.
Preservation of water quality in Horsepen Creek is
largely the responsibility of the local governments in the area.
As part of a program to preserve water quality, it is recommended
that the appropriate governmental bodies initiate the following:
development of a Section 208 planning
program,
a regular water quality monitoring program
for Horsepen Creek and Lake Brandt,
a comprehensive runoff control ordinance,
restriction of any development in the fresh-
water marsh at the confluence of Horsepen
Creek and Lake Brandt,
2-18
-------
legal restrictions preventing future tie-ins
to the Horsepen Creek interceptor system be-
yond its design capacity,
acquisition of lands for recreation and
conservation,
multiple use of interceptor corridor for
recreation and conservation, and
the preservation of water quality in the area
will also be greatly enhanced by the continued
strict enforcement of the Guilford County septic
ordinance and the sub-division ordinance restrict-
ing any development within the Horsepen Creek
floodplain.
Minimizing adverse impacts related to land use will
require Greensboro and Guilford County officials to plan for a
particular growth scenario and implement control measures to
ensure that development follows the plan. The Master Plan
currently under consideration is a step in that direction. The
"Open Space Program" of January, 1977, and the "Land Use Goals
and Policies" statement of Guilford County demonstrate the desire
of county officials for balancing development interests with
environmental considerations.
In short, it appears that many of the control measures
required to promote orderly land use and prevent development in
environmentally sensitive areas are already in existence in some
form or are under consideration. Strict enforcement of existing
measures together with the institution of the additional measures
proposed will provide a comprehensive program for water quality
protection.
2-19
-------
3.0
REVISIONS TO THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
Several changes are required in the Draft EIS to re-
flect alterations in the project since the DEIS was issued and
to incorporate changes resulting from comments on the DEIS. The
revisions indicated below incorporate the most important revi-
sions required; minor or insignificant alterations are not in-
cluded. Revisions in response to comments are generally included
only if the changes are not adequately or compeletly expressed
in Chapter 4 of this Final EIS.
3.1 Wastewater Flows
3.1.1 Domestic and Commercial Flows
The population of the Horsepen Creek Basin was origi-
nally estimated as of 1975 in the Greensboro-Guilford County,
North Carolina 201 Wastewater Treatment System Draft EIS (EN-R-
618) at 8,080 persons. It was felt that a significant change
had occurred since that time, so a new survey and revised esti-
mate were made in February 1979. This survey consisted of a
windshield count of all residences in the basin. The number
of residences was then multiplied by sl standard occupancy rate.
As a result of this, it was estimated that the current population
of the Horsepen Creek Basin is approximately 13,830 persons.
Domestic and commercial wastewater flows (including allowable
infiltration/inflow) were estimated on the basis of 70 gallons
per capita per day (gcd). Therefore, the domestic and commercial
component of the flows was raised from 0.57 million gallons per
day (MGD) to 0.97 MGD in this Final EIS.
3.1.2 Industrial Flows
It was presumed in the DEIS that all present and future
industrial flows would be segregated and handled by the Albert
3-1
-------
Pick lift station. It was determined that this would not be
cost effective, and therefore the present and committed future
(letters of intent) industrial flows of 0.78 MGD were added to
the Horsepen Creek Interceptor. This included an estimated 0.15
MGD for future tie-in of the Greensboro-High Point Airport. The
letters of intent must be followed up with legally binding let-
ters of commitment before the Step III construction grant is
issued. If this is not done, the local agencies must pay to
have the line redesigned to a smaller size.
3.1.3 Institutional Flows
Guilford College currently discharges to the Guilford
College lift station service area. To accomodate wastewater
from present and future enrollment, 0.09 MGD was added as in-
stitutional flow.
3.1.4 Other Flows
The Cardinal #2 lift station currently handles a small
flow from another basin. Since it is located close to the site
of the proposed new lift station, it should logically drain by
gravity to this station. The 0.02 MGD currently handled by
Cardinal #2 was thus included in sizing the new lift station.
The Albert Pick lift station currently handles 0.14
MGD from the Deep River Basin. Since it was determined that
Albert Pick would not handle the industrial flow from Horsepen
Creek, the flow to this station was reduced from 1.1 MGD to 0.15
MGD present and committed future flow.
3.1.5 Summary
The flows that were used in the design of the collec-
tion lines for this FEIS are summarized in Table 3-1.
3-2
-------
TABLE 3-1. FLOW SUMMARY (By Service Area) FOR
HORSEPEN CREEK INTERCEPTOR
Flow Component
Stagecoach Wagon Guilford British
Total Trail Wheel College Pinetop Woods Balance
Domestic and Commercial
Including I/I
.968
.020
.463
.088
.123
.116
.158
Industrial (Existing)
.310
.310
(Letters of Intent)
.304
.304
Airport (1995)
.153
.153
Institutional
TOTALS
OTHER:
Cardinal #2
.090
1.825
.024
.787
.463
.090
.178
.123
,116
.158
Albert Pick Service
Area
Present
Letters of Intent
.144
.010
ALBERT PICK TOTAL
.154
-------
3.2
Collection Line Sizes
Primarily,as a result the changes in design flows (as
discussed in Section 3.1), the pipe sizes for the gravity sewers
and force mains in the proposed Horsepen Creek collection system
were recalculated. Since the final evaluation only involved
those alternatives which served the existing population,,new
calculations were performed on Alternatives IE, 2E, 3E, 4E, 5,
and 6 only. The line-sizing methodology employed was identical
to that described in the DEIS.
Since the proposed new lift station is to recieve flow
from the present Cardinal #2 lift station, several changes in
the line configuration were required as follows:
re-locate new lift station to east side
of U.S. 220 (Alternatives 1 through 4);
change Line 8 to Line 8A and add Line 8B,
gravity sewer, to drain from end of Line
8A to re-located new lift station (Alter-
natives 1 through 4);
add Line 14, gravity sewer, to drain from
present site of Cardinal #2 lift station
to site of new lift station (Alternatives
1 through 4); and
add Line 15, force main, as relief line
to parallel existing six-inch force main
from Wagon Wheel lift station to Stage
Coach Trail lift station (Alternatives 3
through 6).
3-4
-------
These changes are reflected in the revised schematic figures
presented in Chapter 2. Figures 2-2, 2-3, 2-4, 2-5, 2-6, and
2-7 replace Figures 3-1, 3-2, 3-3, 3-4, 3-5, and 3-6 respectively
in the DEIS. Figure 2-3 also replaces Figure 2-1 in DEIS.
The revised design sizes for the sewer line segments
are summarized in Table 3-2. This table supersedes Table 3-1,
page 25 of the DEIS. Detailed analyses of the sewer line seg-
ments for Alternatives IE, 2E, 3E, 4E, and 6 are presented in
Tables 3-3, 3-4, 3-5, 3-6, and 3-7.
3.3 Cost Analysis of Alternatives
Due to the changes in sewer line sizes and configura-
tions, a revised cost anlaysis of alternatives was prepared.
Costs were calculated as described in Section 3.3 of the DEIS.
Net present value was calculated on the basis of 6 7/8 percent
APR, as promulgated by the U.S. Water Resources Council on
1 October 1978, over a 20-year design period (1980-2000).
The revised costs or tne various alternatives are
presented in Table 3-8. This supersedes Table 3-3 on page 41
of the DEIS.
3-5
-------
1
2
3
4
5
6
7
8c
81
9
10
11
12
13
14
15
TABLE 3-2. DESIGN SIZES FOR SEWER LINE SEGMENTS
(Diameter in Inches)
Alternative No. Line Length
IE 2E 3E 4E 5 6 (feet)
15
14
4,100
21
18
11,200
8
8
8
8
5,000
21
21
12
12
6,000
8
¦ 8
8
8
9,000
8
8
8
8
900
10
10
10
10
5,000
27
24
14
14
4,400
27
24
15
15
800
8
8
8
8
5,000
8
8
8 1,000
12
12
1,000
20
20
10
10
8,600
8
8
8 12,000
8
8
8
8
2,600
8
8 8
8 2,200
3-6
-------
TABLE 3-3. DESCRIPTION OF HORSEPEN CREEK WASTEWATER
TRANSMISSION LINES (Alternative: IE)
Peak
Line Diameter Design Capacity at Length No. of Slope
No. Designation (inches) Flow (cfs) 2/3 Full (cfs) (feet) Manholes (ft/100 ft)
1
Gravity
15
2.913
3.142
4,100
13
0.41
2
Gravity
21
4.396
5.945
11,200
34
0.26
3
Gravity
8
0.293
1.014
5,000
13
1.08
4
Gravity
21
4.740
4.875
6,000
18
0.18
5
Gravity
8
0.551
0.850
9,000
23
0.78
6
Gravity
8
0.381
1.029
900
3
1.11
7
Gravity
10
0.981
0.991
5,000
13
0.35
8a
Gravity
27
5.771
7.239
4,400
13
0.11
8b
Gravity
27
6.130
7.756
800
3
0.125
9
Gravity
8
0.359
1.296
5,000
13
1.70
10
Gravity
-
—
—
1,000
3
1.50
11
Gravity
12
1.433
1.944
1,000
3
0.50
12
Force Main
20
7.4
—
8,600
-
—
13
Force Main
-
—
—
12,000
-
—
14
Gravity
8
0.074
1.246
2,600
7
1.58
-------
TABLE 3-4. DESCRIPTION OF HORSEPEN CREEK WASTEWATER
TRANSMISSION LINES (Alternative: 2E)
Peak
Line Diameter Design Capacity at Length No. of Slope
No. Designation (inches) Flow (cfs) 2/3 Full (cfs) (feet) Manholes (ft/100 ft)
1
Gravity
14
2.437
2.620
4,100
13
0.41
2
Cravity
18
3.919
3.970
11,200
34
0.26
3
Gravity
8
0.293
1.014
5,000
13
1.08
4
Gravity
21
4.263
4.875
6,000
18
0.18
5
Gravity
8
0.551
0.850
9,000
23
0.78
6
Gravity
8
0.381
1.029
900
3
1.11
7
Gravity
10
0.981
0.991
5,000
13
0.35
8a
Gravity
24
5.293
5.311
4,400
13
0.11
8b
Gravity
24
5.653
5.690
800
3
0.125
9
Gravity
8
0.359
1.296
5,000
13
1.70
10
Gravity
8
0.477
1.211
1,000
3
1.50
11
Gravity
12
1.433
1.944
1,000
3
0.50
12
Force Main
20
6.9
—
8,600
-
—
] 3
Force Main
8
0.6
—
12,000
-
—
14
Gravi ty
8
0.074
1.246
2,600
7
1—
U"i
00
-------
TABLE 3-5. DESCRIPTION OF HORSEPEN CREEK WASTEWATER
TRANSMISSION LINES (Alternative: 3E)
Peak
Line Diameter Design Capacity Length No. of Slope
No. Designation (inches) Flow (cfs) 2/3 Full (cfs) (feet) Manholes (ft/100 ft)
1
Gravity
—
—
—
4,100
—
—
2
Gravity
—
—
—
11,200
—
—
3
Gravity
8
0.343
1.014
5,000
13
1.08
4
Gravity
12
0.393
1.248
6,000
18
0.22
5
Gravity
8
0.551
0.850
9,000
23
0.78
6
Gravity
8
0.381
1.029
900
3
1.11
7
Gravity
10
0.981
0.991
5,000
13
0.35
8a
Gravity
14
1.424
1.629
4,400
13
0.17
8b
Gravity
15
1.783
1.826
800
3
0.15
9
Gravity
8
0.359
1.296
5,000
13
1.70
10
Gravity
—
—
—
1,000
—
—
11
Gravity
¦ —
—
—
1,000
—
—
12
Force Main
10
2.2
—
8,600
-
—
13
Force Main
—
—
—
12,000
-
—
14
Gravity
8
0.074
1.246
2,600
7
1.58
15
Force Main
8
1.7
—
2,200
-
—
-------
TABLE 3-6. DESCRIPTION OF HORSEPEN CREEK WASTEWATER
TRANSMISSION LINES (Alternative: 4E)
Line
No.
Designation
Diameter
(inches)
Peak
Design
Flow (cfs)
Capacity at
2/3 Full (cfs)
Length
(feet)
No. of
Manholes
Slopi
(ft/100
1
Gravity
—
—
—
4,100
—
—
2
Gravity
—
—
—
11,200
—
—
3
Gravity
8
0.343
1.014
5,000
13
1.08
4
Gravity
12
0.393
1.248
6,000
18
0.22
5
Gravity
8
0.551
0.850
9,000
23
0.78
6
Gravlty
8
0.381
1.029
900
3
1.11
7
Gravity
10
0.981
0.991
5,000
13
0.35
8a
Gravity
14
1.424
1.629
4,400
13
0.17
Bb
Gravity
15
1.783
1.826
800
3
0.15
9
Gravity
8
0.359
1.296
5,000
13
1.70
10
Gravity
8
0.477
1.211
1,000
3
1.50
11
Gravity
—
—
—
1,000
--
—
12
Force Main
10
2.2
—
8,600
—
—
13
Force Main
8
0.6
—
12,000
—
—
14
Gravity
8
0.074
1.246
2,600
7
1.58
15
Force Main
8
1.7
—
2,200
—
—
-------
ine
o.
1
2
3
4
5
6
7
8a
8b
9
10
11
12
13
14
15
TABLE 3-7. DESCRIPTION OF HORSEPEN CREEK WASTEWATER
TRANSMISSION LINES (Alternative: 6)
Peak
Diameter Design Capacity at Length No. of
Designation (inches) Flow (cfs) 2/3 Full (cfs) (feet) Manholes
Gravity
Gravity
Gravity
Gravity
Gravity
Gravity
Gravity
Gravity
Gravity
Gravity
Gravity
Gravity
Force Main
Force Main
Gravity
Force Main
0.477
0.6
1.7
1.211
4,100
11,200
5,000
6,000
9,000
900
5,000
4,400
800
5,000
1,000
1,000
8,600
12,000
2,600
2,200
-------
TABLE 3-8. COST OF ALTERNATIVES
Net Present Value
Alternative No. Capital ($ million) O&M ($ thousand/yr) ($million) (rank)
IE 2.1 15 2.0 5
2E 2.1 15 2.0 5
3E 1.1 28 1.3 3
4E 1.3 29 1.4 4
5 0.2 31 0.5 1
6 0.3 31 0.6 2
-------
3.4 Errata
Other appropriate corrections to the DEIS are itemized
in this section. Those items which have already been discussed
in detail in Sections 3.1, 3.2, and 3.3 are not included in this
itemization.
Page
xv i
Location
Paragraph 1
Revision
Insert the following sentence at the end
of grant conditions:
Upon completion of the proposed action,
the existing systems of lift stations
and force mains will be removed from
service.
Paragraph 1 Change total project capital cost to $2.1
million. Change annual O&M costs to $15
thousand.
Paragraph 1 Delete third sentence from the end.
6 Paragraph 2 Change first sentence to read as follows:
Facilities for the proposed action are
designed to transfer approximately 1.0
MGD of domestic and commercial flow and
0.8 MGD of industrial and institutional
flow from the Horsepen Creek Basin to
the North Buffalo Basin for treatment.
Approximately 0.2 MGD from the Deep River
Basin will be transferred to the South
Buffalo Basin via the Albert Pick lift
station.
6 Paragraph 2 Change the lift station capacity (second
sentence) to 4.4 MGD.
7 Paragraph 3 Change to read as follows:
A new 200 horsepower lift station will
be constructed east of U.S. Highway 220
with a peak capacity to deliver approxi
mately 4.4 MGD.
3-13
-------
Page
Location
Revision
7 Paragraph 6
9 Table 2-1
10 Page 10
12 Paragraph 1
12 Paragraph 2
23 Figure 3-7
23 Figure 3-7
26 Paragraph 2
30 Paragraph 3
Change estimated electricty consumption
(second sentence) to 700 thousand kwhr.
Replace Table 2-1 with Table 3-4 of this
chapter.
Replace entire page with Section 5-2 of
this Final EIS.
Change number of alternatives (first sen-
tence) to six. Change second sentence to
read as follows:
"No Action" and "Modified No Action" are
included as two of these alternatives.
After "No Action" add: and "Modified No
Action" alternatives
Change title to read as follows:
Future Growth Areas In the Horsepen
Creek Basin, and Domestic and Commercial
Wastewater Flows By Subbasin.
Change "E" flow values starting at the top
of the page and proceeding clockwise as
follows:
E-0.158, E=0.080, E=0.026, E-0.010,
E=0.123, E=0.088, E=0.020
Change "No Action Alternative" (second sen-
tence) to:
"No Action" and "Modified No Action" al-
ternatives.
Fourth sentence, change reference to:
(RA-R-667).
3-14
-------
Pag
40
64
64
79
89
101
101
101
101
102
102
Location
Paragraph 1
Revision
Change fifth sentence to read as follows:
A trend factor of 1.5 was applied to
construction and O&M costs of lift sta-
tions to bring numbers into current
dollars.
Paragraph 1
Last line, change maximum depth to ap-
proximately 36 feet.
Paragraph 3
Third sentence, change reference to:
(RA-R-667).
Paragraph 5
Second sentence, change "mean depth of 36
"feet" to: maximum depth of 36 feet.
Paragraph 2
Paragraph 2
Delete fourth sentence.
At end of third sentence add:
and a growth of 4,870 persons from the
1979 population of 13,830.
Paragraph 2
Fourth sentence, change number of people
to 4,870.
Paragraph 3
Paragraph 4
Delete entire paragraph.
First sentence change number of people to
4,870.
Paragraph 1
First sentence, change number of people
per household to 3.5. Second sentence,
change number of acres to 1,391.
Paragraph 2 Delete first sentence. Change third sen-
tence to read as follows:
Thus, 360 acres (industrial and commercial)
plus 1,390 acres (residential) or a total
of 1,750 acres will be developed through
the year 2000 under the proposed action.
3-15
-------
Page Location Revision
103
Paragraph 1 First line, change number of acres projected
to change to 1,750.
3-16
-------
4.0
RESPONSES TO COMMENTS RECEIVED
Due to the large number of individuals commenting on
the Draft EIS and the considerable overlapping of their concerns,
the Agency has responded to these comments generally according
to identified categories of concern. The comments from all
commenters were assigned to one or more of these categories.
However, much of the material presented in the comments was
a restatement of information presented in the Draft EIS or only
a preference for or against a certain alternative, and no Agency
response to that material is explicitly made. To identify com-
menters with the various concerns expressed, each commenter has
been assigned a numerical designation as follows:
1. Campbell, F. E.
2. Clapp, F. L.
3. Corbett, R. T.
4. Deal, 0.
5. Duckwall, T.
6. Blanchard, B.
7. Elliot, A. L., Sr,
8. Hicks, J. L.
9. Hubert, T. E.
Chairman of the Board, County
Commissioners, Guilford County
Greensboro Board of Realtors
Vice Chairman, Council on Economic
Development, Greensboro Chamber of
Commerce
Guilford County Commissioner
T. Gilbert Pearson Audubon
Chapter: Greensboro, NC
Director Environmental Project
Review: U.S. Department of Interior
Citizen
State Conservationist, USDA
Chairman: Council on Community
Development and Planning, Greensboro
Chamber of Commerce
10. Jezorek, J. R.
Environmental Action Coalition
4-1
-------
11. Schott, M.
12. Johnston, A.
13. Kauranen, A. 0.
14. Allen, C. S.
15. Levenson, M. J.
16. Lewis, H. B.
17. Lutz, P. E.
18. Lutz, P. (Ms .)
19. Hagann, Dr. D. P.,
20. Melvin, C. E.
21. Melvin, J.
22. Rees, J. R.
23. Souther, R. H.
24. Yarbrough, J. E.
25. Taylor, A.
26 . Shaw, R. E., Jr.
Jaycees, President
Community Development Manager,
Greensboro Chamber of Commerce
Regional Engineer, Federal Energy
Regulatory Commission
President: League of Women Voters
Citizen
Citizen
Advisory Board for Environmental
Quality: Guilford County
Sierra Club: Joseph Le Conte
Chapter
III Superintendent Guilford County
School System
President, Greensboro Chamber of
Commerce
Mayor, Greensboro, North Carolina
Soil Scientist, Physical Environ-
ments Analysts, Inc.
Citizen
Regional Environmental Officer,
HEW Region IV
North Carolina Division of Policy
Development
Assistant Director of Public Works,
Greensboro, North Caroina
4-2
-------
27. Hight, A. A.
28. Lee, J. H.
29. York, F.
30. Sekadlo, R.
Colonel, Corps of Engineers,
District Engineers
Regional Environmental Officer,
Department of the Interior
Greensboro-High Point Homebuilders
Greensboro-High Point Airport
Authority
The following three major categories were used to
organize the comments:
Engineering Design
Water/Air Quality Impacts
Economic and Human Resources Impacts
The remainder of this chapter is devoted to the responses
to the comments received.
4-3
-------
4.1 Engineering Design
Commenters: 1, 3, 9, 11, 12, 16, 21, 22, 23, 28
4.1.1 Comment
The USGS topographic maps used in the draft environ-
mental impact statement, l"-2000', were inadequate.
Response
The Agencies believe these maps, supplemented by field
observation, are appropriate and suitable for the limited purposes
of the EIS. The Agencies recognize that only approximate grades
(slopes) and alignments of candidate sewer lines can be discerned
from such maps, but these are useful for the preliminary planning
of the EIS' environmental engineering investigation. (Indeed,
7%-minute USGS quadrangles are often the only maps available for
such purposes.) In the later stages of this investigation, the
existence of a more detailed topographic survey, performed as
part of a previous study of Horsepen Creek interceptor alterna-
tives, was brought to light. This survey was used to refine the
grades and alignments for the main stem of the interceptor system
and served as a basis for revised cost estimates in this Final EIS.
4.1.2 Confluent
The Draft Environmental Impact Statement gives excava-
tion depths of from 5 to 10 feet for sewer pipes. At present
pipe diameters, the depths will go down to 20 feet over a length
of 5000 feet. This will cause an unacceptable increase in the
price of this project.
4-4
-------
Response
Excavation to 20 foot depths is certainly technolo-
gically feasible and there are no criteria presented to gauge
what is or is not an "acceptable" increase in the cost of
this project. However, the Agencies concur that excavation
depths should be minimized by a combination of prudent pipe
alignment and pipe sizing that promotes efficient wastewater
transmission. Using revised slopes and pipe sizes, the pre-
liminary engineering presented in the Final EIS indicated maxi-
mum excavation depths of ten feet.
4.1.3 Comment
The size of the sewers did not allow for industrial
us ers.
Response
The comment is misleading. The proposed Horse-
pen Creek Interceptor is designed to transmit all existing
wastewater flow from industries in the Horsepen Basin and
from industries whose wastewaters currently are introduced to
the existing system. In addition, in accordance with EPA
policy and guidelines, the proposed system is designed to
accommodate those future industrial flows that have been
specified in "letters of intent" (conditioned upon a firm
agreement for such requirements in "letters of commitment"
before detailed engineering plans are complete).
4-5
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4.1.4 Comment
Wastewater generation from the Brush Creek Basin
(the Cardinal Corporation system) to the north should be handled
by the Horsepen lift station rather than retaining the Cardinal
lift station in such close proximity to the proposed system.
Response
The Agencies concur with this observation. In the
Final EIS, a line is recommended to carry the wastewater flow
from the Cardinal station to the proposed Horsepen lift station.
Cost of this line is included in alternatives 1 through 4 (all
alternatives with a Horsepen lift station); increased pumping
capability" required is negligibly small.
4.1.5 Comment
The use of 70 gcd (gallons per capita per day) is
inappropriate in computing flow projections.
Response
The state of North Carolina allows a maximum of
70 gcd of domestic and commercial flow for planning purposes.
Of this 70 gcd, approximately 10 gcd is included as the commer-
cial component. An analysis of commercial water billing re-
cords indicated a commercial component of less than half that
amount in the HC Basin. The Agency believes that 70 gcd
is an ample per capita flow contribution, and is consistent
with the experience of the Greater Greensboro area.
4-6
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4.1.6 Comment
No attention was given to serving industrially zoned
undeveloped land in the Deep River Basin.
Response
Since the Deep River Basin was not in the 201 area
covered in the draft environmental impact statement, it was
not addressed, in accord with Agency regulations.
4.1.7 Comment
The system should be designed to accommodate flows
from the airport.
Response
Flows from the airport are considered in the final
environmental impact statement and are allowed for as a
designated future wastewater component in the engineering
analysis.
4.1.8 Comment
The flow of existing lift stations was not checked
or used.
Response'
This aspect of the Horsepen Interceptor EIS has
been discussed at several technical coordination meetings with
the City, EPA, State of North Carolina, and their consultants.
The representativeness of the flow data specified for use and
4-7
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the proper phasing of flows from the various stations in the
system could not be determined without reservations. Consequently,
the design flow analysis 'was not based on lift station data
but on standard per capita flow contributions and an updated
population forecast disaggregated to subbasins. The results
were compared to the test data from the existing lift stations
and were found to be reasonable and consistent, and provided
an ample margin of safety in the estimate.
4.1.9 Comment
The treatment facilities at the Lake Townsend Filter
Plant should be more fully addressed.
Response
The Horsepen Creek Basin and the effect of its develop-
ment upon Lake Brandt was the focus of this investigation.
Lake Townsend is downstream from Lake Brandt and any negative
changes in water quality affect the quality of Lake Townsend
water. However, a complete analysis of Lake Townsend water
quality and the facilities at the Lake Townsend Filter Plant
was not necessary to ascertain adverse effects on the water sup-
ply in Lake Brandt.
4.1.10 Comment
The Draft Environmental Impact Statement does not
address the provision for potential flows from existing, but
temporarily unoccupied, industrial facilities or for an in-
crease in load from current users.
4-8
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Response
Committed future industrial flows, whether from existing
or new users, have been accounted for in the FEIS.
4.1.11 Comment
The statement that industrial waste is not handled by
the Stage Coach Trail life station is erroneous.
Response
It was initially planned that the present industrial
flows, which all originate within the Stage Coach Trail subbasin,
would be segregated and handled by the Albert Pick lift station.
It was subsequently decided that this would not be cost effective.
In the FEIS, all industrial flows have been retained in the
Horsepen Creek basin.
4.1.12 Comment
The draft environmental impact statement does not
address the ability of the Albert Pick lift station to pump
the much greater distance to the South Buffalo outfall.
Respons e
It is anticipated and included in revised cost es-
timates that pump capability will be increased at the Albert
Pick lift station when the new force main is constructed.
There is very little wastewater currently associated with this
component of the proposed system, and the additional cost is
very small.
4-9
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4.1.13 Comment
The impact of the wastewater flows from the Horsepen
Creek basin on the North and South Buffalo Creek Treatment Plants
and the effects of the flow of treated effluent on receiving
streams should be discussed.
Response
The Environmental Impact Statement completed during
December of 19.77 on the Greensboro-Guilford County 201 Plan
(EPA document number 904/9-77-037) discussed the potential im-
pact of wastewater flows from the Horsepen Creek basin on the
wastewater treatment plants and on the receiving stream. The
treatment plants are properly sized to handle this flow and
no adverse impact is expected to the receiving stream with the
levels of treatment proposed.
4.2 Water/Air Quality Impacts
Commenters: 1, 2, 7, 8, 14, 15, 17, 20, 21, 22, 25
4.2.1 Comment
Stormwater management, zoning regulations geared to
the protection of Lake Brandt and a monitoring system are needed
for the Lake Brandt area.
Response
The Agencies encourage but cannot require such prudent
measures as part of the wastewater interceptor grant conditions.
A more complete list of measures recommended to mitigate growth
4-10
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related water quality impacts is given in Chapter 5 of this
Final EIS. Citizens interested in the implementation of these
measures should work with their local governments in this regard.
4.2.2 Comment
10 to 15 percent of precipitation infiltrating to
cause ground-water recharge is probably overly optimistic.
Response
The regional water budget is poorly known. The sus-
tained yield estimates are based on recent work of the Ground-
Water Section of the North Carolina Department of Natural
Resources and Community Development and on estimates made by the
U.S. Geological Survey. The recharge rate almost certainly ex-
ceeds the current and anticipated withdrawal rates. It is recog-
nized that an increase in impervious cover will slightly reduce
the recharge rate, but this appears to be an academic concern.
4.2.3 Comment
The federal mandate to ultimately eliminate the use of
leaded gasoline should be addressed in the discussion of the pro-
jected lead loading levels in Lake Brandt.
Response
The source(s) of lead in the Lake Brandt watershed and
their relative importance are not currently known. While a re-
duction in the use of leaded gasoline may ultimately reduce
lead loadings to Lake Brandt, this eventuality cannot be ac-
curately determined as to whether, when, and to what extent it
will occur. The uncertainties concerning this question contribute
to the need for a monitoring system in the Greensboro watershed.
4-11
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4.2.4 Comment
Mitigating measures were only recommended. They should
be implemented prior to construction of the interceptor to help
protect Lake Brandt and Horsepen Creek.
Response
This was not considered necessary, since the selected
alternative does not encourage additional growth. Furthermore,
these recommendations must be initiated and carried out over
the long term at the local level of government. The North
Carolina Department of Natural Resources and Community Develop-
ment will be conducting statewide 208 work in the Lake Brandt
area in the coming year.
4.3 Economic and Human Resources Impacts
Commenters: 1, 2, 3, 8, 9, 11, 19, 20, 21, 22, 23, 28
4.3.1 Comment
Limiting the commercial or industrial acreage is against
the stated National Urban Policy of supplying jobs in urban areas.
Response
The National Urban Policy is designed to supply jobs to
workers in areas of unemployment. This aim can be accomplished
in the Greensboro area by rejuvenation of existing commercial and
industrial facilities as well as by construction of new facilities
in less environmentally sensitive areas than the Horsepen Creek
Basin.
4-12
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4.3.2 Comment
There is no mention in the DEIS of the planning board
policy (adopted May 11, 1977) not to recommend residential densi-
ties greater than 20,000 ft2/dwelling unit (% acre).
Response
This was discussed in the report, "Investigations of
Water Quality Impacts Related to Development of the Horsepen Creek
Basin, Guilford County, North Carolina" (RA.-R-507). Lot sizes
were presumed to be % acre under a sewered development scenario
and one (1) acre under a septic tank development scenario.
4.3.3 Comment
The limited and no growth alternatives make it more
costly to provide transportation, and both educational and
recreational facilities.
Response
On a per capita basis these costs might be increased.
However, total expenditures for support services for this area
under Alternative 2E will probably be less than expenditures
under the full growth options. In addition, the cost of pro-
tecting the quality of Lake Brandt water is most probably less
than the cost of finding a new supply of municipal water. These
added expenses would increase the total cost of any full develop-
ment plan.
4-13
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4.3.4 Comment
No data are given to support the DEIS assertion that
septic tank regulations are not strictly enforced in the Horsepen
Creek area.
Response
The Draft Environmental Impact Statement does not as-
sert that septic tank regulations are not strictly enforced in
the Horsepen Creek area but, rather, that in the future these
ordinances must be followed to avoid adverse impacts from im-
propertly functioning septic tanks (DEIS, pp. 31, 107). The
reference to this ordinance is made because the chosen alterna-
tive encourages further residential development on septic sys-
tems; not because of any identified deficiency in the county's
enforcement procedures.
4.3.5 Comment
The population in the basin will continue to grow even
if a limited or no growth option is taken.
Response
With proper zoning restrictions there is no reason the
basin should grow any more than the county government believes
is appropriate and compatible with the protection of Lake Brandt.
The local government has the power to limit growth in the region
and is the appropriate agency to use land use control measures
to carry out a comprehensive land use planning program.
4-14
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4.3.6 Comment
The use of demographic projections encourages the locat-
ing of numbers of persons, who may or may not be present at a
future time, in natural areas physically unsuited for this type
of land use.
Response
Demographic projections are based on current trends
and indicate a possible future scenario. Whether this antici-
pated growth actually occurs is a function of the control the
local governments have over development and local economic con-
ditions . Projections are estimates and as such can also point
out the undesirable consequences of following a particular course
of action and enable the regulating organizations to alter those
courses with the most adverse effects.
4.3.7 Comment
With a system designed solely for current needs, the
remaining dwellings would need to be served by septic systems,
further adding to the deterioration of Lake Brandt.
Response
The County Health Department's comprehensive septic tank
ordinance, when strictly enforced, will minimize the effects of.
septic systems upon the Horsepen Creek Watershed. As the DEIS
states (p. 31), the ultimate impacts to the watershed will be
less utilizing a combination of septic tanks and collectors/lift
stations/force mains than by strictly utilizing a sewerage system.
The County's septic tank ordinance is technically sound and should
minimize direct adverse impacts,
4-15
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4.3.8 Comment
The low-density development proposed will severely
restrict the developers' ability to effect economies of building.
Response
The limitation of residential development to larger
lot sizes will tend to increase housing costs in the basin.
This is a necessary tradeoff to maintain water quality in Lake
Brandt. This effort to protect the watershed should not effect
housing costs in other developing areas of Guilford County.
4.3.9 Comment
Installing the Horsepen Creek Interceptor will likely
encourage and speed housing construction in the watershed of
Lake Brandt.
Response
The Horsepen Creek Interceptor (2E) is designed for
existing population only. This limited sewerage combined with
effective local control through zoning restrictions will not
cause an increase in housing in the Lake Brandt watershed.
4.3.10 Comment
The basin is the community's primary growth center for
population and industry, limited growth would severely affect
the economy of the entire region.
4-16
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Response
The chosen alternative in the Draft Environmental
Impact Statement is that which would have the least adverse
effect on Lake Brandt. Limiting residential development in
this basin should not significantly affect the region's economy
since many other areas are available for residential develop-
ment which are not in the watershed. All industrial users
which produce the proper letters of intent and letters of com-
mitment will be provided with service. The degradation of the
water supply would have a far greater impact on the region's
economy than limiting growth in the Horsepen Creek basin.
4.3.11 Comment
If the DEIS 2E configuration is inaccurate, then the
operation and maintenance (O&M) cost projections are probably
inaccurate.
Response
Revised O&M cost projections are included in the Final
Environmental Impact Statement.
4.3.12 Comment
The DEIS states that cultural resources will be con-
sidered prior to construction. These resources should be con-
sidered in the early planning stages according to 40 CFR, Part
6.
4-17
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Response
Cultural resources were considered in both the 201 plan
and in the Draft EIS to assure minimal conflicts between any
proposed wastewater facilities and any cultural facilties. A de-
tailed archeological survey will be performed during the design
(Step II) of the wastewater planning and construction program.
EPA's Region IV standard procedure for compliance with
the National Historic Preservation Act of 1966, the Archeological
and Historic Preservation Act of 1974, Executive Order 11593,
and Title 36 CFR 800 is to perform reconnaissance on treatment
plant sites during Facility Planning (Step 1) and to perform
reconnaissance on interceptor lines during preparation of Plans
and Specifications (Step 2). This procedure has been instituted
since the exact location of interceptor routes is not known un-
til on-site surveys have been performed on approval of Step 1
(Facility Planning), presentation of the impact on archeological
resources from interceptors is not appropriate at this time.
The major alternatives associated with facility plan-
ning concern the backbone facilities, that is, the treatment
plants' site locations and the general location of interceptor
corridors. Once the plants have been located, there are multiple
potential alignments which require detailed investigations to
determine the most cost' effective environmentally sound configu-
ration. The level of detail required to determine these exact
alignments is more appropriate for Step 2. As soon as an en-
gineeringly sound alignment has been determined, an archeological
reconnaissance is performed. In the major of cases, the align-
ment can then be shifted to avoid cultural resources. If the
alignment cannot be adjusted, consultation with the Advisory
Council is initiated.
4-18
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The EIS states on page 5-3 that awarding of grant
funds for construction will not occur until an archeological
reconnaissance has been performed and approval has been received
from EPA. Prior to approval, the consultative process contained
in "Procedures for the Preservation of Historic and Cultural
Properties", 36 CFR 800, will be followed as per our standard
procedure.
There also will be minimal conflicts with both exist-
ing and proposed recreation sites. In fact, the opportunity of
utilizing the Horsepen Interceptor right-of-way as a multipurpose
project is being investigated by Guilford County as a result
of this EIS.
4-19
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5.0
AGENCY DECISION
This chapter delineates the proposed action to be pur-
sued further in Step 2 activities and stipulates the conditions
that must be met for Step 2 funding.
5.1 Conclusions
The Environmental Protection Agency and the North
Carolina Department of Natural Resources and Community Develop-
ment have chosen Alternative 2E as the proposed action. This
alternative involves:
abandonment of all lift stations in the
Horsepen Creek (HC) basin except the
Albert Pick lift station,
construction of HC interceptor and collec-
tion lines (at a size to serve existing needs)
to abandoned lift stations,
construction of a new force main from the
Albert Pick lift station to new outfall dis-
charging to the South Buffalo Creek collection
system, and
construction of a new lift station and force
main near U.S. Highway 220 to transfer HC
interceptor wastewater to the North Buffalo
Creek collection system.
This proposed action was chosen as the result of an
alternatives evaluation conducted during the EIS process.
5-1
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The results of this alternatives evaluation show that
the most significant impacts from this project are to water quality
and land use. Selection of the "No Action" or "Modified No Action"
alternatives would encourage low density development throughout
the basin. The existing service alternatives would also generally
tend to encourage low density development. The future service
alternatives will provide for much higher development densities'
throughout the basin. In the short term, this development will
probably be concentrated adjacent to those areas that are cur-
rently developed. Ultimately, development will occur throughout
the basin.
The less intensive land use densities of existing ser-
vice alternatives will minimize the concentration of pollutants
generated in urban runoff. These alternatives will have a signi-
ficantly smaller potential adverse impact to water quality in
Lake Brandt .than the future service alternatives with their sub-
stantially higher land use densities.
Other potential adverse impacts to water quality could
result from the existing system of lift stations and septic tank
failures. The "No Action" and "Modified No Action" alternatives
would not alleviate these potential hazards. Alternative IE and
2E would do the best job in this regard by eliminating all but
one lift station.
Alternative 2E is considered the most environmentally
acceptable alternative since it alleviates the existing problems
with the smallest encouragement of high density development. There-
fore, Alternative 2E has been selected as the proposed action.
5-2
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5.2
Step 2 Grant Conditions
As a result of this Environmental Impact Statement
and- the Step 1 Facilities Plan activities, the agency will require
certain actions as conditions to receiving Step 2 grant funds.
These Step 2 grant conditions are delineated as follows:
• Potentially affected areas will be surveyed
to determine the presence of possible archaeo-
logical resources. This survey will be ac-
complished during the Step 2 process and the
survey plan and results will be subject to
approval by the North Carolina State Historic
Preservation Officer and State Archaeologist.
If possible,and complying with good engineering
practices, interceptor lines should be con-
structed completely out of or on the edges of
the floodplain. This condition should be
evaluated during Step 2.
An erosion and sedimentation control plan must
be submitted to DNRCD and EPA for approval.
This plan should meet the requirements of the
Soil Conservation Service (see comment letter)
and the Guilford County Soil and Water Con-
servation District.
• The maintenance of a 30-foot vegetative buffer
between the edge of construction rights-of-way
and stream banks will be required where feasible.
• The immediate revegetation of interceptor rights-
of-way will be required.
5-3
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Upon completion of the proposed action, the
existing system of lift stations and force
mains will be removed from service.
In addition, it is recognized that other mitigating
measures are important to the protection of water quality in
this area. Therefore, it is recommended that the appropriate
governmental bodies initiate the following:
development of. a Section 208 planning program,
a regular water quality monitoring program for
Horsepen Creek and Lake Brandt,
a comprehensive runoff control ordinance,
multiple use of the interceptor corridor for
recreation and conservation.
restriction of any development in the freshwater
marsh at the confluence of Horsepen Creek and
Lake Brandt,
legal restrictions preventing future tie-ins to
the Horsepen Creek interceptor system beyond
its design capacity, and
• acquisition of lands for recreation and conserva-
tion, and
5-4
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The preservation of water quality in the area will
also be greatly enhanced by the continued strict enforcement
of the Guilford County septic tank ordinance and the county
subdivision ordinance restricting development within the Horse-
pen Creek floodplains.
5-5
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6.0
BIBLIOGRAPHY
EN-R-687 Environmental Protection Agency, Region IV, Greensboro-
Guilford County, North Carolina 201 Wastewater Treat-
ment System, Final Environmental Impact Statement, EPA
Contract 68-01-3436, Atlanta, Georgia, 1977.
RA-R-667 Radian Corporation, Investigation of Water Quality
Impacts Related to Development of the Horsepen Creek
Basin, Final Report, EPA Contract No. 68-01-3436,
Austin, Texas, August 1977.
RA-R-671 Environmental Protection Agency, Region IV, Greensboro-
Guilford County, North Carolina Horsepen Creek Inter-
ceptor, Draft Environmental Impact Statement, EPA
Project No. C37036901, Atlanta, Georgia, September
1978.
6-1
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APPENDIX A
WRITTEN COMMENTS ON THE DRAFT EIS
-------
POBResr e CAMPBELL, CHAIRMAN
BERT a HALL.vtce chairman
OGDEN DEAL
'•••ASTON d, faison
j- bOQERT LANDRETH.jR.
GUILFORD COUNTY
Board of GotmHj Commissioners
P. O. BOX H427
Greensboro, North Carolina 27-W2
JOHN V WITHERSPOON
COUNTY MANAGT.R
WILLIAM 8. TREVORROW
COUNTY ATTOONEY
ANNIE F. PARHAM
CLERK TO BOAR;!) ,
November 20, 1978
Mr. John White, Regional Administrator
Region IV
Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30308
Dear Mr. White:
On behalf of the Board of County Commissioners of Guilford County, I request
that this letter be made part of the record of the November 20, 1978, Public
Hearing on the "Draft Environmental Impact Statement, Greensboro-Guilford
County, North Carolina, Horsepen Creek Interceptor, EPA Project No. C37036901 .
Our general reaction to the Draffs conclusions is contained in my oral presen-
tation at the Hearing. I have attached a written copy of those remarks.
More specifically, I have listed below items contained in the Draft about
which we have serious concerns:
-We feel the use of 70 gallons per day per capita is too low in
computing flow projections.
-The assumption that all industrial waste by-passes the Stage Coach
Trail Lift Station is erroneous.
-Wastewater generation from the Brush Creek Basin (The Cardinal Corp.
System) to the north should be handled by the Horsepen Lift Station
rather than retaining the Brush Creek Station in such close proximity
to the. proposed System.
-The System should be designed " accomodate flows from the Airport
Terminal Complex (60,425 gpd by 1985, 153,000 gpd by 1995).
-According to flow figures provided recently by the City of Greensboro
According to IJ-° » ~ o the 2E Svstem as described in the
fron on-site monitoring fl~ muck iess "limited" growth
Draft could not accomodate today s now, muuu
in the future.
-------
Mr. John White
November 20, 1978
Page Two
-The Draft should Incorporate, in much more concise terms, the mitigating
measures for secondary impacts available to and utilized by local
government, i.e., Zoning Ordinance, Watershed Designation, Subdivision
Control Ordinance, PTCOG's "Regional Land Development Guide", Thorough-
fare Plan, Planned Unit Development (cluster) Zone, Open Space Program,
pending Stormwater Management Ordinance, City-County Water and Sewer
Extension Agreement.
-The Treatment capabilities of the Lake Townsend Filter Plant should be
more fully addressed.
-The Federal mandate to ultimately eliminate the use of leaded gasoline
should be addressed in the discussion of projected lead loading levels
in Lake Brandt.
We are disappointed with EPA's selection of a "limited" growth alternative.
We, in Guilford County can, and have, certainly attempted to direct and
regulate growth, but as the Draft points out, the Basin will continue to
develop long after Alternate 2E has reached capacity. Will we then be in
the same predicament in which we find ourselves today?
We respectfully request that the longer-term impact of Basin development
be fully considered before a final decision is made by your Office.
Sincerely yours,
Forrest E. Campbell, Chairman
Board of County Commissioners
Guilford County
FEC/ba
Attachment
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RFMARKS FOR ENVIRONMENTAL IMPACT STATEMENT HEARING
HORSFPFN CREEK INTERCEPTOR SFWFR LINF
November 20, 1978
Gentlemen, we have reviewed the Draft Environmental Impact
Statement and are very concerned about the wisdom of the decision
to select a less than adequate sewer system.
It has been our position since 1966 that this Interceptor Sewer
System be designed to accomodate the existing and full future
development of the Basin. This remains our position today.
The EIS acknowledges the poor suitability of soils in the Basin
to accomodate properly functioning septic tanks. We agree with
THIS FACT.
The EIS states that full development of the Basin will occur
eventually no matter the existence, configuration or capacity
of any public sewer system. We agree with this conclusion.
The EIS assigns detrimental impacts to Lake Brandt from
malfunctioning septic tanks. The EIS points out the sprawl
and inordinate consumption of open space in the Basin associated
WITH DEVELOPMENT ON SEPTIC TANKS. We AGREE WITH THESE CONCLUSIONS
AS WELL.
We STRONGLY DISAGREE WITH THE DOCUMENT S INFERENCE THAT LOCAL
GOVERNMENT HAS AN INADEQUATE DESIRE AND/OR REGULATORY TOOLS TO
GREATLY MITIGATE MANY OF THE SECONDARY IMPACTS CREATED BY FULL
Basin development on public sewer.
-------
- 2 -
Available to us locally is the City-County Water & Sewer
Extension Agreement which provides policy and direction for
MANAGING THESE SERVICES. SlNCE 1964, WE HAVE UTILIZED OUR
ZONING AUTHORITY TO REGULATE TYPES OF DEVELOPMENT. In FACT.
our Planned Unit Development Zone which was specifically
DESIGNED TO PROTECT WATERSHED AREAS AND CREATE OPEN SPACES
WILL NOT WORK UNDER A SEPTIC TANK DEVELOPMENT SCENARIO.
We have our Subdivision Ordinance and our Erosion and Sedimentation
Control Ordinance. A Stormwater Management Ordinance is
presently under consideration. The County and Greensboro
Planning Departments, in conjunction with the Regional Council
of Governments, have been, and remain, involved in long range
planning for the area. Thoroughfare planning in the area has
BEEN ACCOMPLISHED IN CONJUNCTION WITH THE ClTY AND DEPARTMENT
of Transportation.
Our record clearly indicates a vital local concern for water
quality. Many of our developmental zones are specifically
geared to regulate watershed development. We have long
discouraged the location of "wet" industries in our community.
It is, in fact, this concern for Lake Brandt that we feel that
if the Basin is to eventually develop fully, then that development
SHOULD BE PLACED ON PUBLIC SEWER RATHER THAN SEPTIC TANKS.
We ARE CONVINCED THAT THE DECISION TO KNOWING I V INSTALL A
LESS THAN ADEQUATE SYSTEM WILL HAVE GRAVE CONSEQUENCES, BOTH
ENVIRONMENTALLY AND FINANCIALLY, FOR US IN THE FUTURE.
-------
EPA DOES HAVE THE OPTION TO ENDORSE A MUCH MORE SOUND CONCEPT.
We, THE LOCAL LEADERS OF GOVERNMENT, ASK THAT YOU SUPPORT AND
ASSIST US BY EXERCISING THAT OPTION. YOU SHOULD SELECT A SYSTEM
WHICH WILL MUCH BETTER MEET OUR FUTURE NEEDS AND AFFORD
LONGER-TERM PROTECTION THAN THE ALTERNATE CHOSEN IN THE
Draft Environmental Impact Statement.
Forrest E. Campbell, Chairman
Board of County Commissioners
Guilford County
-------
fl-TrfcH/n fa)t XL
HORSEPEN CREEK INTERCEPTOR SEWER
On Monday, November 20th, the Environmental Protection Agency will hold a
Public Hoar-ttig in the Greensboro Coliseum Complex Auditorium.
The purpose of the Hearing i8 to allow interested parties to comment on
the Draft Environmental Impact Statement on the Project.
Attachment 'A' in this package shows the five (5) Alternative Configurations
considered by EPA. Each Alternative could be sized to serve future (F) or
or existing (E) development.
Local government, the Piedmont Triad Council of Governments and, to a great
degree, the State, preferred Alternate IF. This was the System originally
proposed in 1966.
EPA has chosen 2E (see Attachment ,'B'). Note the pipe diameters of EPA'e
proposed System I
Alternate IF is estimated to cost $2.4 million. Alternate 2E is to cost
$1.38 million.
EPA pays 75% of the cost, the State pays 12%Z and the County pays 12%%.
Attachment 'C' is a letter to EPA's Administrator which chronicled our
efforts to date to get the Project going.
When EPA's Administrator visited Greensboro, he alluded to his impression
that local government had neither the tools nor desire to properly regulate
growth in the Horsepen Basin. Attachment 'D' is our response to the Adminis-
trator's concerns.
In late September of this year, it was determined, from actual measurements
in the field, that Alternate 2E as proposed by EPA was grossly undersized
to serve even existing development. City computers and engineers predicted
the EPA system would not only fall short of State construction standards,
but would over flow on the first day of operation.
This information was immediately communicated to EPA and the issue has yet
to be resolved. A November 14th letter from EPA's engineers indicates they
stand firm on their preliminary calculations. They do concede that detailed
engineering may necessitate some changes in their design.
Attachment 'E' is a summary of various County departments' reactions to the
EIS.
Attachment 'F' points out the need for the System to handle the Airport complex-
Attachment 'G' is a Chamber listing of possible new industrial users on the
System.
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-------
administrative
OFFICES
June 6, 1978
Greensboro, N. C.
27402
Mr. John White
Regional IV Director
Environmental Impact Study Branch
U.S. Environmental Protection Agency
34S Courtland Street
Atlanta, Georgia 30308
Dear Mr. White:
A memo is attached which recounts what might fairly be
called "The Sorry Saga of the Horsepen Creek Outfall."
When you visited with us ore May 19, you may have left
with the impression that we were sensitive about this pro-
ject. The memo will provide you with an understanding of
what lies behind our reactions.
Your mention of a 208 Study was the straw that broke our
patience. At several points in the history of this project,
the County (or the City in the case of Metro) was advised
to embark on another course of action with the assurance
that 208 would not be brought in later as an excuse for
further delay. Since we experienced so many delays and
changes in attitude on the part of E.P.A., I really was not
too surprised when you brought 208 in on May 19. Upon
reflection, however, I realize that it was your predecessor
who gave this specific assurance and you are probably unaware
of it. In all likelihood, you are probably not aware of the
complete history of the Horsepen Creek Project. Therefore,
the attached memo was prepared from our files. I only wish
we had recorded all our conversations with officials of
E.P.A., but then we were mere babes in the woods when this
mess began.
Hopefully, you will reconsider your position on Horsepen and
approve the County's recommendation of alternative IF. We
firmly believe in that project from both economic and environ-
mental points of view.
Attachment
-------
rr- J11 —i
Greensbobo, N. C.
June 5, 1978
MEMORANDUM
To: John V. Witherspoon, County Manager
From: Jim Rlckards, Assistant to Manager/OperationsC^*
Re: Documentation of Progress (?) of Grant Application
for Horsepen Creek Interceptor Sewer Line
The assignment to document this project was no easy task. The files
for the State and federal grants for this one Project consume 10*s" of file
cabinet space.
An interesting comparison is to look at the $1.5 million Oak View
Estates Project wheTe we consciously did not apply for federal funds due
to our Horsepen experience. We went only with the 25% State grant. That
Project only consumes 3" of cabinet space and took only 43 months between
Board authorization and project completion.
The Horsepen Project was first formally discussed in our 1966 Land Use
Plan.
It was addressed in more detail in a 1967 Study prepared by Hazen and
Sawyer.
It was one of the named projects in the Bond Referendum of 1971.
The following is a more detailed history of the Project beginning
with the successful Bond Issue.
June 8, 1971 - Bonds approved by voters
October 6. 1971 - State advises to proceed with Grant application in
anticipation of successful Statewide Clean Water Bond Referendum
to be held May of 1972
November 1, 1971 - Commissioners adopt resolution to apply for federal
funds
November 15, 1971 - Board votes to seek Engineering firm
January 17, 1972 - State and EPA determine all Project components are
eligible for funding
February L5, 1972 - Council of Government approves Project
February 19, 1972 - Clearinghouse approves Project
February 22, 1972 - Application submitted
March 2, 1972 - Moore-Gardner retained as Engineers
Eferch * 1972 - State acknowledges receipt of all application documents
May, 1972 - Clean Water Bond Referendum successful
-------
-2-
September 5, 1972 - Concerned over delays State Is experiencing in gearing-up
to administer Bond funds, Guilford requests permission to proceed with
Horsepen construction and receive grant funds on a retroactive basis
September 12, 1972 - State denies "retroactive funding" proposal
October, 1972 - State requests grant be resubmitted on new forms
November 24. 1972 - New application, working drawings and specs submitted
to State
December 15, 1972 - State acknowledges receipt of new application and advises
that only EPA approval of the State's "Interim Subbasin Plan" stands in
the way of project funding
January 18, 1973 - State announces that State grants will be 12*5% since EPA
grant amounts were increased to 75%
April 9, 1973 - State announces its bond attorneys are concerned with
referendum wording and no State monies will be forthcoming until
problem has been resolved
April 27, 1973 - State Commission ranks Horsepen and Greensboro Metro Plant
jointly as #1 priority in State
June 26, 1973 - State submits its "Interim Subbasin Plan" to EPA
July 31, 1973 - Greensboro Record headlines state Horsepen turned down by
EPA because Interim Plan was unacceptable. News story was first
indication to County that there was a problem. Fiscal year 72-73
funding deadline was August 1, 1973.
August 13, 1973 - State advises County that it was not informed of EPA's
intent to deny Project and had yet to be informed
August 17, 1973 - Congressman Preyer informs County that he had "good news".
EPA has assured him that "grant will be forthcoming in reasonable
period of time".
September 5, 1973 - State reaffirms that Horsepen still #1 priority in State
and that State will push for grant
September 10, 1973 - EPA states Greensboro Metro and Horsepen Projects must
be combined as one Project
September 13. 1973 - EPA meets in Raleigh with State, County and City
officials, investigation shows that reason State Plan was disapproved
was due to absence of requested supporting documents. Turned out
documents in question had been sent and received by EPA
November 15. 1973 - State ranks Metro/Horsepen as if 1 priority in State for
F.Y. 73-74 funding
January 7. 1974 - Environmental Assessment Hearing held
January 11» 1974 - County retains Moore-Gardner to prepare Environmental
Assessment Statement
January 16, 1974 - State Office of Environmental Planning states it has just
heard of Horsepen Project and requests detailed update
January 21, 1974 - Commissioners adopt new resolution applying for increased
grant amounts due to inflationary increases resulting from delays
February 6, 1974 - 201 Hearing held
February 28, 1974 - State approves revised cost figures and increases grant
amount
April 30, 1974 - EPA tells State it will approve grant if Greensboro gives
written commitment that level of treatment at S. Buffalo Plant will
be improved
-------
-3-
Mav 5, 1974 - Completed Environmental Assessment Statement submitted to
State
May 8. 1974 - Greensboro sends written commitment to State regarding treatment
at S. Buffalo Plant
August 12. 1974 - EPA approves working drawings and specifications, instructs
County to advertise for bids
August 19, 1974 - EPA submits official grant offer
August, 1974 -Environmental Coalition files suit against EPA requiring an
EIS
September 3, 1974 - Commissioners accept grant offer
September 6, 1974 - County advises EPA it will join EPA in litigation
sppf-Arnhpr 18, 1974 - EPA telephones County and instructs Guilford to hold
—offon advertising for bids until further word
September 19, 1974 - County receives executed grant agreement from EPA
September 23. 1974 - EPA counsel advises County to refrain from advertising
for bids until litigation is more settled
All of-1975 spent in litigation
February 17, 1976 - EPA Administrator meets with State, City and County and
advises that EPA will settle out of court by preparing an EIS and that
both Metro and Horsepen will be addressed in same Statement. EPA to
prepare Scope of the Work and select consulting firm as soon as
possible.
August 19. 1976 - State advises that Clean Water Bond Fund almost exhausted
by other projects and balance cannot be held in trust for Horsepen
awaiting EPA's EIS
September 21. 1976 - BADIAN retained by EPA. RADIAN states it will take six
months to complete EIS
July 12. 1977 - EPA states that Horsepen EIS is far from completion and that
previous decision to have one Statement for both Projects will be reversed.
EPA will proceed with Metro first, then prepare a separate Statement for
Horsepen.
July 13. 1977 - County appeals decision and requests that Horsepen retain joint
priority. Appeal denied.
September 1. 1977 - Metro EIS Hearing held
March 15. 1978 - EPA meets with County to review EIS draft
April 3. 1978 - Commissioners express preferred Alternative as //IF **
April, 1978 - Greensboro Council express preferred Alternative as if IF
Mav 19. 1978 - EPA Administrator meets with interested parties and
advises that he is "leaning toward" Alternative #2E or No Action
Mav 23. 1978 - Mayor and Chairman jointly request Administrator reconsider
decision
JR:lfm
-------
UPDATE OF JUNE 5, 1978 MEMO
HISTORY OF HORSEPEN
June 26. 1978 - Administrator states he will not reconsider and has
decided on "2E".
July 24, 1978 - County requests EPA to advise as to date of Hearing.
September, 1978 - City of Greensboro monitors actual wastewater flows
in Horsepen System.
September 27. 1978 - Greensboro Engineer advises RADIAN has made mis-
calculation in sizing System. System will over flow first day of
operation.
October 4. 1978 - County & City advise EPA of RADIAN miscalculation.
EPA schedules Hearing for November 20th.
October 5. 1978 - EPA official visits Greensboro. Delivers EIS Draft.
Staff requests meeting with RADIAN to discuss miscalculation.
October 23. 1978 - County again requests meeting to discuss miscalcu-
lation. Reminds EPA of Airport and potential industrial flows.
November 6. 1978 - Chairman Campbell writes Administrator. Requests
EPA/RADIAN reaction to Greensboro's findings.
November 9. 1978 - RADIAN responds to Greensboro findings in writing.
NoyamKer 14. 1978 - EPA agrees to meeting on afternoon of 20th to
discuss findings.
-------
;s*EST C. Cams3^l.Cha,3wan
JOHN V. WITHCRSPOON
COUNTY MAMACCft
gra- A. HALL,V'.-^C
GUILFOKD COUXTY
Board of Cotmltj- Commissioners
WILLIAM 0. THCVORPQW
COUNTY ATTOrnse*
ANNIE F PARHAM
CLCPH TO SOAPC
. CCSaftT LANOSiT--. .
P. 0- Box 3427
Greensboro, North Carolina 27402
May 23, 1978
Mr. John White, Regional Director
U. S. Environmental Protection Agency, Region IV
345 Court!and Street
Atlanta, Georgia 30308
Dear John:
Thank you very much for the interest you have shown in our Horsepen
Creek Interceptor Sewer Project. We appreciate your taking the time to
personally come to Greensboro and hear both sides of the argument.
We sincerely believe that either of the alternatives which you
mentioned-you were leaning toward would be a mistake. And, very
respectfully, we believe that your staff is unaware of all of the
factors which play a part in this project. As an example we would
point out the following facts:
1. The City and County have had in effect, since 1965, a
joint agreement that defines the area which we would
serve with water and sewer and thus helps to control
and/or direct growth insofar as possible.
2. The County has since 1954 had zoning authority in this
area. It has exercised subdivision controls since 1965.
One condition of this subdivision control involves the
requirement that flood plains are to be designated as
easements. This is similar to the City requirements and
even a cursory trip around the City would indicate how
effective this has been.
3. Greensboro and Guilford County were among the first to
adopt soil erosion and sediment control ordinances. These
have been in effect since 1975 and are more stringent (and
better enforced) than the State's requirements.
4. Effective July 1, 1978, the County will enforce regulations
dealing with permanent downstream protection of stream banks
and channels and control of stormwater runoff.
-------
Mr. John White
Page Two
May 23, 1973
5. The City and County, by resolution adopted June 2, 1977,
asked the Corps of Engineers to make an Urban Water Resources
Study for this area. This, as we understand it, would dovetail
into any future 208 planning but would save some of the time
involved.
6. Both the City and County have indicated repeatedly that every
effort would be made to promote and channel growth into the
area East and Northeast of the City. However, we are realists
enough to know that it will take time to change this growth
direction. With the construction of Metro we will be in a
position to intensify our efforts in this direction but frankly
we feel that much development will take place in the Horsepen
basin prior to this change. Provision for this limited growth
is essential.
7. As discussed during our meeting the Pick pumping station is
on the High Point watershed. All of the problems associated
with it which would be trtfe on the Greensboro watershed would
also be true with this location.
8. The local share for this project is to be provided by general
obligation bonds. This bond issue was overwhelmingly approved
by the voters of Guilford with the Horsepen Project being
named as one of the major endeavors for which the funds
would be used.
9. The Piedmont Triad Council of Governments has endorsed the
Project as being in keeping with regional plans and, in fact,
PTCOG's "Regional Land Development Guide" recognizes the
project and plans for it accordingly.
There was much conversation concerning 208 planning and the fact that
this had not been started in this area. Very frankly we believe that our
land use planning, density control, and workable pollution control is
further advanced than that in the Raleigh-Durham area where 208 planning
has been proceeding for some.four years. Further, we would certainly
intend to perfect our additional controls in accordance with better
Planning whenever a workable model is shown. So far we have not seen that.
However we have, as mentioned above, requested the Corps of Engineers to
make a study and this request has been approved.
We would like to remind you that very recently both the City Council
and Board of County Commissioners, by a formal vote, reaffirmed their
commitment to the project as being in the best interest of their citizens.
In view of the above facts and in order to handle our situation in
the best possible way we respectfully request that you designate alternate
IF as the preferred alternate.
-------
Mr. John White
Page Three
May 23, 1978
Again thank you for your help and your obvious desire to do the best
job possible for everyone concerned.
Sincerely
Jim lvin
Mayo
Chai rman
County Commissioners
cc: Honorable Richardson Preyer
-------
s|c=r
ADMINISTRATIVE
OFFICES
Greensboro, N. C.
27402
MEMORANDUM
October 25, 1978
To: John V. Witherspoon, County Manager
From: Jim Rickards, Assistant to Manager/Operation
Be: Staff Comments - Horsepen Draft EIS
Planning
-RADIAN use of 70 gallons per day per capita is too low.
-Proposed action (2E) will not accommodate existing development.
-No attention given to serving industrially-zoned, undeveloped
land in Deep River Basin.
-"Mitigating Measures" chapter implies that septic tank regulations
are not strictly enforced. No documentation to support implication.
-EIS cites need for thoroughfare plan in Basin. Thoroughfare Plan
was adopted by N. C. Board of Transportation on June 6, 1977. It
provides for Airport-Benjamin Parkway linkage.
-No mention of Planning Board policy (adopted May 11, 1977) not to
recommend residential densities greater than 20,000 ft.^/d.u.
Soil Scientist
-EIS employs superfluous "filler material" such as discussions of
endangered species of wildlife and sensitive plants when none are
known to inhabit basin.
-RADIAN use of 70 gallons per capita per day is low.
-10Z-15Z of precipitation infiltrating to cause ground water recharge
is probably overly optimistic.
-Adoption of a Basin Stormwater Management Plan could mitigate much of
the potential threat to Lake Brandt.
The 2E configuration:
-Does not provide for the new airport terminal or other airport
facilities.
-Does not provide for a tie-in at the U. S. 220 North lift station
for the flow from Cardinal.
-Does not address the ability of the Pick lift station to pump the
much greater distance to the South Buffalo Outfall.
Operation*
-------
John V. Witherspoon
October 25, 1978
Page Two
-Does not address the provision for potential flows from existing,
but temporarily unoccupied industrial facilities.
-The Draft actually projects that after the System has reached capacity
that an additional 6,620 persons (2000 dwelling units) will have to
utilize septic tanks when it also states that the Basin's soils are
unsuitable for long-term septic tank use.
-The Draft does not address what will happen should existing (on-line)
industrial/commercial users desire to expand their facilities or go
to two or three shift operations.
In all probability the capital and 0 & M cost projections are inaccurate if
the present 2E configuration is faulty.
The Draft states excavation depths for pipes will be from 5 to 10 feet. We
have already determined that if EPA remains with present pipe diameters the
depths will go to 20 feet over a length of 5,000 feet.
The Section, "Existing Water Quality and Trophic State of Lake Brandt"
(pg. 64) is filled with conjecture and assumptions. Phrases like, "...Should
be carefully examined...", "...It is possible...", "Sources...unknown", "It
is probable...", etc. It appears that the Draft is attempting to address
a subject about which insufficient research was conducted.
Due to the apparent miscalculations by RADIAN on 2E sizing, I feel their
references to the existing system as being "grossly oversized" now have
doubtful credibility.
We have yet to receive EPA's reaction to Greensboro's findings on actual
flows in the Basin. I intend to call Harold Duhart this week to find out
what's going on.
JR/ba
-------
/,/<•
tb't*
J r
C**
i— 11 r=r
4~lisc|w«i" T
administrative
OFFICES
Greensboro, N. C.
27402
October 23, 1978
Mr. Harold Duhart, Project Manager
North Carolina Section
Water Division
U. S. Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30303
Re: Horsepen Creek Interceptor Sewer Line
Project C370369, Guilford County
Dear Mr. Duhart:
As a followup to my letter to you of October 4th I wanted to advise your
office of additional factors which should be addressed as you review our
findings on current flows in the Horsepen System.
Besides the additional flow which will be generated by "limited" future
residential growth as well as existing homes in the basin presently on
septic tanks, the Airport Authority anticipates discharging an additional
60.425 gpd into the Horsepen System by 1985. Maximum flow from the Airport
will reach153,000 gpd by 1995.
The City's monitoring figures do not reflect any generation from the present
vacant American Can Company facility. However, the Chamber informs me that
a new potential firm may occupy this structure. The firm will employ about
250 persons and will generate only domestic waste.
I will submit letters from the Airport Authority and Chamber verifying
these projections shortly.
I hope this additional information will be of some help.
John V. Witherspoon, County Manager
Greensboro Chamber of Commerce
Airport Authority
Ray Shaw, City of Greensboro
Larry Harvell, Director of Environmental Services
Jim Rlckards
Assistant to Manager/Operations
JR/ba
-------
November 10, 1978
Mr. James C. Rickards
Assistant to Manager-Operations
Guilford County
Post Office Box 3427
Greensboro, North Carolina 27402
Re: Horsepen Creek Interceptor Sewer
Dear Jim:
In earlier correspondence you requested information on industrial growth in
the Horsepen Creek basin, particularly in the airport area.
As you are well aware, the airport area is the primary focus of the community's
industrial development activity. Only through continued expansion of industry
and business in that area can our community continue to maximize employment
opportunities for all residents.
A number of firms have recently announced plans to locate in the area which will
increase significantly sewage system capacity requirements.
1. The Weyerhaeuser Company has moved into a new 80,000 square foot
distribution facility from an older building within the same area
of about 15,000 square feet.
2. The Limitorque Corporation has a new building under construction
where over 100 will be employed within one year.
3. George Sharpe Is completing a 40,000 square foot distribution
facility, a portion of which is now occupied. We anticipate over
40 employees at that location.
4. Several major national concerns have recently reviewed the American
Can Company building on American Avenue. Two of these firms have
a real interest in the building's availability; the smallest would
employ a minimum of 250.
5. While not directly in the basin, the decision by Rockwell International
to consolidate its Rockwell-Draper Division at the Carolina American
Textile building with over 300 employees is illustrative of the type
of success the community is having in its industrial development
activities.
We are most concerned that EPA restrictions on full and proper development of the
Horsepen Creek basin will restrict our ability as a community to provide employment
opportunities for all residents. Such action by EPA would, of course, conflict with
^ the President's directive of maximizing employment opportunities in our urban areas.
~
»CCBtPtT*P
-------
Mr. James C. Rickards
November 10, 1978
Page 2
Your efforts to ensure that an interceptor sewer is constructed which is adequate
to serve both existing and future development in the Horsepen Creek basin while
eliminating the health hazards of lift stations and septic tanks is most appreciated.
The Chamber will continue to assist you and other public agency officials and
employees in any way we can to achieve this objective.
Sincerely,
Allan Johnston, Ma _
Community Development
-------
Date:
Sept. 27, 1978
To: Ray Shaw
From:- Don Knibb
Subject: Horsepen Creek Outfall
The pipe sizes as recommended by EPA for the Horse-
pen Creek Drainage Basin have been checked. A computer
model was constructed for the main outfall from the ex-
isting Stage Coach Trail Lift Station to the proposed
Horsepen Creek Pumping Station.
The flow capacities as provided by Holland and
Macklin (EPA) were checked to determine the grade they
proposed for each line. Most grades thus determined
were found not to conform to minimum grades as published
by the State Board of Health.
We then had Moore, Gardner and Assoc. take the pro-
posed line sizes and prepare a profile that would meet
State standards. This put the line very deep, in places
20 feet. Moore, Gardner estimates the construction cost
of the lines would be $1,197,000. This does not include
side lines 3, 5, 6, 7, 9, 10, or 11.
We input the most recent loading of each lift station
with zero growth and found that all line sizes proposed by
EPA were inadequate. In fact, our computer model shows
that on the first day the new system is put in service, the
system will overflow and a parallel line costing $695,000
will be required to correct the problem.
Using the same existing load we have selected pipe sizes
that will handle the load flowing 2/3 full and meet the min-
imum grade requirements. Moore, Gardner and Assoc, estimates
the cost of the main trunk of this line at $658,000.
Additional engineering is required to complete the design
and costing of the lines connecting the lift stations to this
main outfall. The USGS topo maps to a scale of 1" « 2000' are
totally inadequate for this purpose because long flat sections
along the creek bottoms may be missed.
-------
-2-
The sizes developed by the city fail to meet the
stated objectives of the recommended plan, E-2, because
zero growth has been used in choosing the sizes.
Page 11, paragraph 6 of the Radian report shows a
projected population increase of 10,620. Using Radians
70 gped, which is significantly less than the present
blend of development provides, a growth load of 743,400
gpd (516 gpm) ave. flow should be added.. An additional
design was made adding this flow in proportion to avail-
able land. These sizes are shown in the attached table.
Don Knibb
g
attach/
-------
-------
HORSEPEN CREEK INTERCEPTOR
All flows in cu. ft. per second
CITY OF
GREENSBORO DESIGN
EPA
ALTERNATIVE E-2
ZERO
GROWTH
MIN. RADIAN GROWTH
LINE
CONTRIBUTING
LIFT STATION
DATE
EXISTING LOAD
MIN. MAX. AVE.
DESIGN
FLOW*
PIPE
SIZE
2/3
FULL
FLOW
DESIGN
FLOW
PIPE
SIZE
2/3
FULL
FLOV7
SIZE
FLOW
BY
HOLLAND
FLOW
BY
MACKLIN
1
Stage Coach
8/29/78
.33
1.21
.60
1.20
8
1.48
1.53
10
1.74
8
.204
.690
2"
.54
2.31
1.21
2.42
15
2.48
3.30
18
3.67
10
.612
.711
3
.49
10
.76
8
. .101
.970
4
.54
2.31
1.21
2.42
18'
3.67
3.87
21
5.56
lb
.714
.789
5
Guilford College
9/6/78
.15
.51
0.22
.44
8
.51
.51
8
.51
8 ¦
.371
.862
6
Pine Top
9/12/78
.09
.38
.23
.46
8
.59
1.37
12
1.76
8
.371
.683
7
.24
.89
.45
.90
12
.80
1.88
15
2.26
10
.301
.690
8
A
B
.78
.81
3.20
3.67
1.66
1.88
3.32
3.76
21
21
3.91
3.91
5.75
6.41
27
27
7.60
7.60
12
1.112
1.185
9
3ritish Woods
9/20/78
.03
.47
.22
.44
10
0.48
.66
12
0.82
8
.309
1.295
10
Albert Pick
8/29/78
.37
.10
.21
.42
10
.70
.42
10
0.70
10
1,422
1.380
11
Wagon Wheel
9/29/78
.21
1.11
.61
1.22
12
1.24
1.85
15
2.25
8
.408
.711
* Design Flov? = 2 x Ave. Flow
-------
Greensboro Board of REALTORS,® Inc.
REALTOR®
1403 Sunset Drive
P. O. Box 9907
Greensboro, North Carolina 27408
Telephone (919) 373-0962
HORSEPEN GREEK INTERCEPTOR SEWER
11/20/78
I'm Fred L. Clapp of Greensboro Board of Realtors and have been
authorized by its Board of Directors to enter the following statement into
the record.
We will not join the technical issue of correct line sizes, be-
lieving that all agencies involved are properly motivated and possess the
requisite engineering skills necessary to satisfactorily resolve this matter.
It is our understanding, however, that, regardless of the eventual
line size, it is EPA's intent to sewer only the existing population plus
providing limited additional capacity. The proposed action, we believe,
will adversely affect housing and quite possibly the economic stability
of the community.
This summer, the Special Task Force on Housing Costs appointed
by the Secretary of Housing & Urban Development pinpointed excessive
government regulations as a major contributor to the current high cost of
housing. The National Association of Realtors estimates that over regu-
lation currently adds approximately 20% to housing costs, or about $9,000
to the cost of today's median priced new house. Inasmuch as trends in
existing home prices closely follow those of new ones, such over regu-
lation affects all potential home buyers. In response to the study HUD
Secretary Harris has announced, among other actions already underway,
that HUD will work with state and local governments for reasonable
standards for land development and in planning for an adequate supply of
usable land. We submit that the proposed action is an example of such
over regulation and will necessarily increase the cost of housing by in-
creasing the minimum lot sizes and prices and increasing the development
costs for additional streets, power, telephone and gas lines, etc The
low density development proposed will also severely restrict' if not deny
the developer's ability to effect the economies of building clustered
housing or "patio" homes and attached "townhouses for sale" and anart-
ment dwellings.
MEMBER North Carolina Association of REALTORS • NATIONAL ASSOCIATION OF REALTORS
-------
Greensboro Board of REALTORS,® Inc.
1403 Sunset Drive
P. O. Box 9907
Greensboro, North Carolina 27408
Telephone (919) 373-0962
REALTOR®
-2-
In the marketplace, the desirability of residential development
in our northwest section has already been established and we are all
agreed that eventual full development of the basin will occur even on
septic tanks. This low density proposal, however, will further re-
strict the supply and cost of land in a market already characterized by
a tightly controlled supply of land. Further, in such a low density
development it will be more costly for the community to maintain
essential public services such as transportation, schools, recreational
facilities, etc. The resulting increased costs must necessarily be
borne by the taxpayers through increased property taxes and therefore
again increase the cost of maintaining a home.
At a time in our history when low-income families have already
been forced from the private housing market and we are rapidly pricing
middle-America out of the private housing market, the impact of the
proposed action on housing costs should not be ignored.
The most serious economic implication of the proposed action to
the entire community is the implied restriction on industrial development.
We admit to confusion and frustration about the rather casual treatment
of industrial development in the EIS. It is elementary and fundamental
that sound industrial growth is necessary to provide employment oppor-
tunities and to expand the tax base in order to be able to maintain a
reasonable level of local taxation. Substantial public and private in-
vestment has already been made in the airport industrial area and it
would be fiscally irresponsible not to fully utilize the facilities and
land provided by such investment. EPA's consultant states that "any
future industrial development in the basin will not be eligible for
sewerage funding by EPA" and the proposed action would apparently
divert all industrial sewage to the South Buffalo plant. Yet the con-
sultant claims that (industrial) "development is limited primarily by
the size of the collector and outfall sewers in the South Buffalo basin"
and that "system modifications necessary to sewer future industrial
growth and the airport will require at a minimum replacing the major
collectors and outfall sewers to the South Buffalo treatment plant.
The cost of such action would appear to be greatly in excess of that
of the Horsepen Creek interceptor itself and would presumably be
Member North Carolina Association of REALTORS • NATIONAL ASSOCIATION OF REALTORS
-------
Greensboro Board of REALTORS® Inc.
REALTOR®
1403 Sunset Drive
P. O. Box 9907
Greensboro, North Carolina 27408
Telephone (919) 373-0962
-3-
entirely the expense of the community. The proposed action therefore
appears to directly and indirectly impose extreme limitations on the
community's ability to provide for a desirable expansion of industry.
The adverse impact on housing and industrial development re-
sulting from the proposed action are not in the best interests of the
community. We submit that the community will best be served by the
selection of Alternate IF which basically would provide full sewer
service to the entire basin.
We are not unmindful of the potential hazards of development
within any watershed. However, we are not persuaded by the EIS that
the low density dispersal of housing and the addition of 2 ,000-2 ,500
septic tanks to the basin is the proper way to handle development.
The EIS addresses itself to the introduction of pollutants into
Lake Brandt, but is silent concerning the technology of removing pol-
lutants by water treatment methods. The EIS on the one hand addresses
itself to lead loadings in Lake Brandt from automobiles associated with
development in the basin and on the other hand ignores existing govern-
ment regulations that require us to drive less effecient more expensive
cars that are restricted to unleaded gasoline.
In an area of soils poorly suited for septic tank use, it would
seem a reasonable probability that the addition of 2 ,000-2 ,500 septic
tanks to the north section of the basin would in time cause health pro-
blems that could only be corrected by a public sewer system and it
would certainly be more cost efficient to provide the system now'rather
than 20 years from now.
The EIS concedes that "many of the measures required to promote
orderly development of the Horsepen Creek area and preserve the water
quality of Lake Brandt already exist." Indeed, one condition of the
grant is that an erosion and sedimentation control plan must be submitted
to EPA for approval. County regulations dealing with the control of storm
water run off are under study. The Board of Realtors be-
lieves that the County and City can and will implement adequate measures
MEMBER North Carolina Association of REALTORS • NATIONAL ASSOCIATION OF REALTORS
-------
m
Greensboro Board of REALTORS® Inc.
1403 Sunset Drive
P. O. Box 9907
Greensboro, North Carolina 27408
Telephone (919) 373-0962
REALTOR®
-4-
for orderly development and we will support and cooperate with such
reasonable measures as may be required. We submit that local govern-
ments are the proper authorities to control land use and development
regulations within local boundaries.
We further submit that the community must finally recognize the
fact that Lake Brandt cannot be indefinitely counted upon as a major
water supply source, and within the 20 year design period, we must
look beyond our present water storage system for an adequate water
supply.
On balance, therefore, we cannot support the proposed action
as being in the best interests of the community. We urge the Director
to reconsider the recommendation and support Alternate IF.
^EMBER North Carolina Association of REALTORS • NATIONAL ASSOCIATION OF REALTORS
-------
Statement of
Rhodes T. Corbett, Vice Chairman
Council on Economic Development
Greensboro Chamber of Commerce
Presented
Monday, November 20, 1978
At An
EPA Public Hearing
On the Draft Environmental Impact Statement
for Wastewater Facilities in the Horsepen Creek Basin
I am Rhodes Corbett, Vice Chairman of the Greensboro Chamber of Commerce Council
on Economic Development. I am here to state our concern about the potential adverse
economic impact of an interceptor sewer improperly sized for the Horsepen Creek basin.
The basin is the community's primary growth area. Its population exceeds 8,000.
By the year 2000 the population is expected to exceed 18,000. It is also the com-
munity's primary industrial growth area. In the properties near the airport over
3,000 acres are zoned for industrial use. Over 600 acres are currently used for
industrial purposes. The 2,400 available acres of industrial zoned land constitute
the community's largest single concentration of such property and consequent new job
opportunities.
According to the Draft EIS, there appear to be constraints placed upon com-
mercial and Industrial development, with prior reports having suggested a limitation
of 210 acres of commercial development and 150 acres of industrial development being
allowed by the year 2000. This type of land use decision can best be made by the
appropriate local governments in- response to demand for such land and a consideration
of the community s best interests. Any limitation of commercial or industrial acreages
on an arbitrary basis by any federal agency is inappropriate. Such a position by any
federal agency would be contrary to the President's National Urban Policy objective of
creating new jobs in our urban areas. In addition, such arbitrary decisions are not .
consistent with the President s policy of establishing a new "urban partnership"
between the public sector and the private sector which will foster the creation of
new jobs.
-------
- 2 -
In summary, the Chamber takes the following position:
1. Responsible public agencies should construct a sewer
adequate to serve existing and future development since
the area continues to be the most desirable area for
residential and related development.
2. Continued industrial development in the airport area is
essential to the economic strength of the community and
to creation of new jobs.
3. Local governments are the appropriate agencies for exercis-
ing development decisions as to the extent and type of land
use to be allowed within the basin.
4. There appear to be reasonable alternatives to protect Lake
Brandt for the period of time which it will continue to be
needed as a water supply reservoir.
Let me again emphasize what our Chamber of Commerce President Charles Melvin
said: If EPA does not concur in the Chamber's position, then we urge that an
agreement be reached between EPA and Guilford County to provide an interceptor sewer
and other wastewater collection system facilities sufficient to serve an appropriate
level of development consistent with a meaningful cost-benefit analysis of land
development and related factors within the Horsepen Creek basin•
Thank you.
-------
FORREST E. CAMPBELL, CHAlRMAh
BERT A. HALL,VICE CHAIRMAN
OGDEN DEAL
GASTON D. TAISON
J. ROBERT LANDRETH, JR.
GUILFORD COUNTY
Board of Coanftf Commissioners
P. O. BOX 3437
Gbeensboho, Nobth Carolina 27402
JOHN V. WITHERSPOON
COUNTY MANAGER
WILLIAM B. TREVORROW
COUNTY ATTORNEY
ANNIE F. PARHAM
CLERK TO BOARD
November 27, 1978
Mr. John C. White
Regional Administrator
Region IV
United States Environmental
Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. White:
I want to reiterate my personal view that water quality
and reasonable environmental concerns should be the
priority consideration in planning for the future of
the Horsepen Basin in Guilford County. t alsn that
the following points be made a part of the record
1.
x »
A vast majority of the undeveloped land in the basin
is zoned A-l - Agricultural. This gives local government
the opportunity to encourage low density growth by a
commitment to retain current zoning patterns.
2.
If development pressures in the area persist and if
full urban services are provided, annexation'should be
undertaken at an early date Indeed, I am becoming
convinced that the county and city water and sewer
policies have, in general, encouraged and subsidized
urban sprawl with the resultant deterioration of the
inner city of Greensboro.
3_.
Even though the soils of the Horsepen Basin are not
the best for optimum septic tank operation, the soils
«« ofth? solls in southern
iiun%Td. cTSswi;s asigFo«^&rri!2o vready
and some parts of Sedgefield have se^ous^epUc tank"'
K?"*X s^e\n ^L'n^T th" th* "°™nts
nave, m some instances, not done a particularly good
-------
Mr. John C. White
November 27, 19 78
Page Two
job in planning or regulation of growth and development.
Further, the communities of Mt. Zion and Franklin
Boulevard have had serious water and sewer problems
for decades. Even though these problems have not been
dealt with in a concerted, effective manner, I believe
existing problems should be dealt with first. The
policies of the past should be changed, where necessary,
to prevent repeating the mistakes of the past.
4_.
Just recently, Guilford County and the City of Greensboro
have agreed to expend $1.5 million in public monies
to provide water and sewer to the Reedy Fork Basin, which
is downstream of the municipal water reservoir northeast
of Greensboro. This action opens up thousands of acres
to industrial, commercial, and residential growth. At
least two thousand acres can be initially, served by this
extension. Opening this vast new area toVdevelopment, with
virtually all urban type services, should alleviate much
of the developmental pressures in the environmentally
sensitive Horsepen Basin. This should be particularly true
for industrial growth. Indeed, a recent survey by the
Chamber of Commerce shows that 91.3% of the 128 members
surveyed desired that industrial growth take place outside
the northwest quadrant. (This, of course, is taken out
of context, as was the references to the same survey at
the hearing of November 21; therefore, I am enclosing the
entire survey results for your information.) Also enclosed
is a copy of the soil survey of Guilford County, which
documents the various soil types in our area.
Please consider these matters when making your final
decisions on the Horsepen Basin dilemma.
Sinrsrp1v.
O^fcfen Deal
Guilford County Commissioner
Enclosures
-------
Greensboro Chamber of Commerce
Poai Offica Box 3246.217 North Qre«ne Greensboro, North Carolina 27402. Telephone 91$ 275-8675.
November 9, 1978
To: Board of Directors
From: Larry Roland, Chairman
Ambassadors Club
Enclosed is the tabulated results of the Ambassadors Club survey for 1978.
The survey was conducted during the three day period of September 12 - 14.
A total of 23 volunteers conducted personal interviews with 211 randomly
selected Chamber members to determine their expectations and desires re-
garding community-wide development over the next five years.
A structured questionnaire was used during the interviews. The question-
naire was developed in cooperation with the Councils on Economic Develop-
ment, Community Development and Planning, and the City and County Planning
Departments. The results are representative of the opinions of 95% of our
members within a 4% margin of error.
An open-ended question regarding the area's strengths and weaknesses is not
being reported at this time as it requires additional analysis. Likewise,
a question regarding local labor market deficiencies requires additional
analysis although we are reporting the basic results to you.
¦10V ,
... *8 1973
-------
Question:
How long have you lived in the community?
Total Responses
211
(100%)
Less than one year
7
(3.3%)
1-5 years
32
(15.2%)
6-10 years
23
(10.9%)
11-15 years
24
(11.3%)
more than 15 years
113
(53.6%)
not a resident
12
(5.7%)
Question:
How long have you lived in your present location?
Total Responses 211 (100%)
Less than 1 year 19 (9.0%)
I-5 years 69 (33.5%)
6-10 years 27 (12.5%)
II-15 years 32 (15.0%)
more than 15 years 58 (27.2%)
not a resident 6 (2.8%)
AGE (Estimated)
20-40 years
41-60 years
61-70 years
over 70 years
67 (33.0%)
120 (59.1%)
13 (6.4%)
3(1.5%)
(Total number of respondents whose ages were estimated is 203.)
-------
Question:
In which quadrant do you live?
Total
City 145
County 51
Combined Totals 196
Northeast Southeast
12 (8.3%) 1 (0.6%)
5 (9.8%) 7 (13.7%)
17 (8.7%) 8 (4.1%)
Southwest Northwest
14 (9.7%) 118 (81.4%)
21j41.2%) 18 (35.3%)
35 (17.9%) 136 (69.4%)
Demographic Analysis
Age Group
20-40 years 56
41-60 years 116
61-70 years 13
over 70 years 3
ages unknown 8
6 (10.7%) 2 (3.6%)
10 (8.6%) 6 (5.2%)
1 (7.7%)
13 (23.2%) 35 (62.5%)
19 (16.4%) 81 (69.8%)
2 (15.4%) 10 (76.9%)
1 (33.3%) 2 (66.7%)
Length of Resi-
dence in Community
Less than 1 year 6 1 (16.7%) 3 (50.0*) 2 (33.3«)
I-5 years 32 1 1,3.11) 1 3.U) g (ls 6ij 25 (78.2j;)
6-10 years 23 2 (8.7%) 1 (4.3%) ? (8 7V) 1R (ik VtS
II-15 years 24 2 (S.3%) 5 (20.8?) 3 (12 5%) 14 5a'«
more than 15 years 111 12 (10.8%) 2J gy ys 703?
Question:
How long have you been with this company?
Total Responses - 211
Age Analysis
61-70 years over 70
2 (4.0%)
1 (3.7%)
10 (12.3%) 3 (3.7%)
Less than 1 year
I-5 years
6-10 years
II-15 years
more than 15 years
9 (4.3%)
50 (23.7%)
40 (19.0%)
26 (12.3%)
86 (40. '
20-40 years
6 (75.0%)
30 (60.0%)
17 (45.9%)
8 (29.6%)
7 (8.6%)
Respondent'?:
41-60 years
2 (25.0%)
18 (36.0%)
20 (54.1%)
18 (66.7%)
61 (75."""
-------
Question:
Please look at this list. If you agree the "quality of life" would include the
items listed, please rate the importance of each item to you. You may add any
items you wish.
Total
Very
Not
Responses
Important
Important
Important
Cost of Living
211
(100%)
126 (59.7%)
81
(38.3%)
4 (2.0%)
Cultural Opportunities
211
(100%)
87 (41.2%)
120
(56.8%)
4 (2.0%)
Educational Facilities
Grades K thru 12
211
(100%)
174 (82.5%)
32
(15.2%)
5 (2.3%)
Post High School
188
(100%)
113 (60.1%)
66
(35.1%)
9 (4.8%)
Environmental Matters
211
(100%)
82 (38.9%)
127
(60.1%)
2 (2.0%)
Health Care
211
(100%)
141 (66.8%)
68
(32.2%)
2 (2.0%)
Housing
209
(100%)
105 (50.3%)
96
(45.9%)
8 (3.8%)
Personal Safety
211
(100%)
137 (64.9%)
67
(31.8%)
7 (3.3%)
Quality of Local
Government
210
(100%)
160 (76.2%)
50
(23.8%)
0
Recreation
211
(100%)
65 (31.8%)
140
(66.4%)
6 (2.8%)
Shopping
211
(100%)
58 (27.5%)
139
(65.9%)
14 (6.6%)
Transportation
210
(100%)
60 (28.6%)
118
(56.2%)
32 (15.2%)
Variety of Occupational
(100%)
100 (51.3%)
o
i—1
<3*
Opportunities
195
80
15 (7.7%)
Question:
In your opinion, has the quality of life improved, remained unchanged, or
deteriorated during the period you have lived in the community?
Total Remained
Responses Improved Unchanged Deteriorated
205 (100%) 148 (72.2%) 24 (16.6%) 23 (11.2%)
Demographic Analysis
Age Groups
20-40 years 66
41-60 years 122
61-70 years 12
over 70 years 3
Length of Residence
in Community
Less than 1 year 6 2 (33.3%) 4 |^6.7%)
I-5 vpars 32 16 (50.0/) 15 (46.9%) 1 (3.1/6)
6-10 vears 23 18 (78.3%) 3 (13.0*) 2 (8.7%)
II-15 vears 24 18 (75.0*) 5 (20.8*) 1 4.2*)
"lore than 15 years 111 90(81.1*) 5(4.5%) 16(14.**
not a resident 9
Location of
Present Residence
Citv 142 104 (73.2%) 21 (14.8%) 17 (12.
County 54 37 (68.5%) 12 (22.2%) 5 (9 *
44
(66.7%)
17
(25.8%)
5
(7.5%)
91
(74.6%)
16
(13.1%)
15
(12.3%)
8
(66.7%)
2
(16.6%)
2
(16.7%)
2
(66.7%)
1
(33.3%)
-------
Question:
As an annual average, how many employees does your firm have in Guilford
County, less High Point and Jamestown?
Total Responses 208 (100%)
Less than 10 employees 82 (39.4%)
11-50 employees 85 (40.9%)
51-100 employees 20 (9.6%)
more than 100 employees 21 (10.1%)
(note: 12 respondents reported employees in ranges from 115 to 5000)
Question:
Will you express an opinion as to what percentage of your employees live:
(in Greensboro, in Guilford County, in another county)
Total Responses - 207
In Greensboro
In Guilford County
In Another County
61.5% (average of all respondents)
30.2% (average of all respondents)
8.3% (average of all respondents)
-------
Question:
If an area around the presently developed Central Business District were
rezoned to provide a Greenbelt of modern townhouses, as shown on the map,
would you consider living in this Greenbelt?
Demographic Analysis
Age Groups
20-40 years
41-60 years
61-70 years
over 70 years
Length of Residence
in Community
Less than 1 year
I-5 years
6-10 years
II-15 years
more than 15 years
not a resident
Location of Present
Residence
City
County
Total
Yes
No
207 (100%)
60
(29.0%)
147
(71.0%)
64
22
(34.4%)
42
(65.6%)
119
34
(28.6%)
85
(71.4%)
14
2
(14.3%)
12
(85.7%)
2
2
(100%)
7
3
(42.9%)
4
(57.1%)
32
9
(28.1%)
23
(71.9%)
22
7
(31.8%)
15
68.2%)
24
4
(16.7%)
20
(83.3%)
110
34
(30.9%)
76
(69.1%)
12
3
(25.0%)
9
(75.0%)
145
45
(31.0%)
100
(69.0%)
51
13
(25.5%)
38
(74.5%)
Question:
(IF "NO") Would another type of housing in this area appeal to you?
Total Positive Responses - 14
(Preference was for single family dwellings)
-------
Question:
Here is a list of possible uses to aid in downtown revitalization. Which
of these uses appeals to you and might attract your patronage? You may
add your suggestions to the list.
Apartments
Banks
Consumer Finance
Entertai nment/Arts
Insurance
Light Manufacturing
Offi ces
Restaurants
Security Dealers
Specialty Stores
Total
Responses
180
(100%)
180
(100%)
171
(100%)
202
(100%)
176
(100%)
170
(100%)
184
(100%)
196
(100%)
181
(100%)
193
(100%)
Yes
77 (42.8%)
121 (67.2%)
84 (49.1%)
181 (89.6%)
116 (65.9%)
53 (31.1%)
153 (83.2%)
186 (94.9%)
132 (72.9%)
150 (77.7%)
No
103 (57.2%)
59 (32.8%)
87 (50.9%)
21 (10.4%)
60 (34.1%)
117 (68.8%)
31 (16.8%)
13 (5.1%)
49 (27.1%)
43 (22.3%)
No
Question:
Do you feel the following items are functions of government in a downtown
revitalization program?
Total
Responses Yes No OpinioH-
Zoning Reviews 211 (100%) 201 (95.3%) 4 (1 g%) 6 (2.8*!
Building Code Reviews 211 (100%) 200 (94.8%) 5 (2*4% 6 izM
Property Tax Structures 211 (100%) 184 (87.2%) 9 (4*3%) 18 (8.$'
Actively Searching for Tenants 211 (100%) 91 (43.1%) 106 (50 2t\ 14 (6.6*1
Direct Financial Subsidy 211 (100%) 64 (30.3%) 140 66*4% 7 3.3*
Tax Incentives 211 (100%) 169 (80.0%) 32 (152%) 10 4-8^'
-------
Question:
If all other factors were equal, would you prefer to park your car downtown
in a parking garage or a surfact parking lot?
Total Parking Surface
Responses Garage Parking Lot
178 (100%) 59 (33.1%) 119 (66.9%)
Demographic Analysis
Age Group
20-40 years
41-60 years
61-70 years
over 70 years
Length of Residence
in Community
Less than 1 year
I-5 years
6-10 years
II-15 years
more than 15 years
not a resident
Location of Present
Residence
City
County
53
19
(35.8%)
34
(64.2%)
104
34
(32.7%)
70
(67.3%)
11
5
(45.5%)
6
(54.5%)
2
2
(100%)
8
2
(25.0%)
6
(75.0%)
27
13
(48.1%)
14
(51.9%)
20
5
(25.0%)
15
(75.0%)
20
7
(35.0%)
13
(65.0%)
97
28
(28.9%)
69
(71.1%)
6
4
(66.7%)
2
(33.3%)
129
42
(32.6%)
87
(67.4%)
43
14
(32.6%)
29
(67.4%)
Question:
Please refer again to this map showing quadrant structure. In what quadrant
would you prefer to see: (industrial growth, commercial growth, residential
growth)
Total
Responses Northeast Southeast Southwest Northwest
Industrial Growth 128 52 (40.6%) 35 (27.3%) 30 (23.4%) 11 (8.7%)
Commercial Growth 113 36 31.9%) 23 (20.3%) 32 (28.3%) 22 (19.5%)
Residential Growth 112 34 (30.4%) 12 (10.7%) 14 (12.5%) 52 (46.4%)
No Preferences 26
-------
Question:
Regarding sources of most of your services and supplies, are these sources
located: (as listed below)
Total Responses
Locally
Within 50 miles
Within the State
Outside the State
Unknown
235
(100%)
79
(33.6%)
41
(17.4%)
40
(17.0%)
74
(31.6%)
1
(0.4%)
Question:
These statistics regarding employment are supplied by the Greensboro and
Guilford County Planning Departments. They are for Guilford County, less
High Point and Jamestown. Employment growth from 1960 to 1974 amounted to
96% over the 1960 figures. Estimated 1990 employment is 30% over the 1974
figures.
In your opinion, is growth of this scale desirable?
•
Total Responses 207 (100%)
Yes 159 (76.8%)
No 33 (15.9%)
No Opinion 15 (7.3%)
Question:
In your opinion, does the local labor market have a substantial deficiency?
Total Responses 206 (100%)
Yes 84 (40.8%)
No 100 (48.5%)
No Opinion 22 (10.7%)
-------
Question:
At present, there are separate school administrations in Greensboro, High
Point, and the rest of the county. In your opinion, should these adminis-
trations remain the same or be consolidated?
Total Remain
^sponses The Same Consolidate
Demographic Analysis
Age Groups
20-40 years
41-60 years
61-70 years
over 70 years
Length of Residence
in Community
Less than 1 year
I-5 years
6-10 years
II-15 years
more than 15 years
not a resident
Location of Present
Residence
City
County
Unknown
191 (100%)
122
(63.9%)
69
(36.1%)
52
30
(57.7%)
22
(42.3%)
118
77
(65.2%)
41
(34.7%)
11
7
(63.6%)
4
(36.3%)
2
2
(100.0%
6
3
(50.0%)
3
(50.0%)
28
23
(82.1%)
5
(17.9%)
23
14
(60.9%)
9
(39.1%)
24
12
(50.0%)
12
(50.0%)
101
63
(62.4%)
38
(37.6%)
9
7
(77.8%)
2
(22.2%)
136
90
(66.2%)
46
(33.8%)
49
32
(65.3%)
17
(34.7%)
-------
Question:
At present, the Greensboro School Board is appointed. In your opinion, should
the members of the Greensboro School Board be appointed or be elected?
Total
Be
Be
Responses
Appointed
Elected
185 (100%)
90
(48.6%)
95
(51.4%)
Demographic Analysis
Age Groups
20-40 years
58
20
(34.4%)
38
(65.6%)
41-60 years
111
61
(55.0%)
50
(45.0%)
61-70 years
10
9
(90.0%)
1
(10.0%)
over 70 years
2
2
(100.0%
unknown
4
4
(100,0%
Length of Residence
in Community
Less than 1 year
7
1
(14.3%)
6
(85.7%)
1-5 years
28
13
(45.4%)
15
(53.6%)
6-10 years
21
9
(42.9%)
12
(57.1%)
11-15 years
22
11
(50.0%)
11
(50.0%)
more than 15 years
98
53
(54.1%)
45
(45.9%)
not a resident
9
3
(33.0%)
6
(67.0%)
Location of Present
Residence
City
136
78
(57.4%)
58
(42.6%)
County
50
13
(26.0%)
37
(74.0%)
Unknown
9
3
(33.3%)
6
(66.7%)
-------
Question:
On a scale of one to ten (ONE is most unsatisfactory, TEN is most satisfactory),
how would you rate your firm's experience with local government regarding regu-
lations, services, and taxes?
Regulations - Total Responses - 191
Rati ng
1 - 4 (2.1%)
2 - 2 (1.0%)
3 - 2 (1.0%)
4-6 (3.1%)
5 - 20 (10.5%)
Services - Total Responses - 190
Rati ng
6 - 9 (4.7%)
7 - 22 (11.5%)
8-39 (20.4%)
9 - 25 (13.1%)
10 - 62 (32.6%)
Rating
1 - 2 (1.0%)
2 - 0
3 - 0
4 - 2 (1.0%)
5 - 12 (6.3%)
Taxes - Total Responses - 186
Rating
1 - 5 (2.7%)
2 - 2 (1.0%)
3 - 5 (2.7%)
4 - 11 (5.9%)
5-33 (17.7%
Rating
6 -
7 -
8 -
9 -
10 -
9 (4,7%)
21 (11.1%)
53 (27.9%)
33 (17.5%)
58 (30.5%)
Rati ng
6 -
7 -
8 -
9 -
10 - 38 (20.4%)
10 (5.4%)
18 (9.7%)
(24.3%)
(10.2%)
45
19
No Experience - 10 (4.7%)
Question:
On the whole, do you feel local governments (city & county) encourage new
business establishment & growth?
Yes No
Total Responses
188 (100%) 165 ( 87.8%) 23 (12.2%)
-------
11-20-78
STATEMENT TO EPA ON DRAFT EIS
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
PEP ER-78/1052
OCT 2 7 1978
Mr. John C. White
Regional Administrator, Region IV
Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30308
Dear Mr. White;
This is in regard to your transmittal of October 5, 1978,
requesting the Department of the Interior's review and comment
on the draft environmental statement for Horsepen Creek Inter-
ceptor, Guilford County, fJorth Carolina.
This is to inform you that the Department will have comments
but will be unable to reply within the allotted time as we
have just received the additional copies of the draft state-
ment which are necessary for our Departmental review.
Our comments should be available by late December.
Bruce"'Blanchard, Director
Environmental Project Review
-------
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COMMENTS BY THE ENVIRONMENTAL ACTION COALITION ON THE DRAFT ENVIRONMENTAL IMPACT
STATEMENT AT THE PUBLIC HEARING ON NOVEMBER 20, 1978 ~~
THE ENVIRONMENTAL ACTION COALITION IS A GROUP OF LOCAL CITIZENS AND ORGANIZATIONS
WHOSE MAIN CONCERN IS THE PRESERVATION OF THE WATER QUALITY OF THE LAKE BRANDT
RESERVOIR. WE ARE NOT AGAINST ORDERLY GROWTH IN OUR COMMUNITY, BUT WE DO REALIZE
THAT AN URBANIZED WATERSHED CAN BE HAZARDOUS TO THE HEALTH OF THOSE WHO DEPEND
UPON IT FOR DRINKING WATER, AND GREENSBORO WILL BE DEPENDENT ON LAKE BRANDT FOR
MANY YEARS TO COME.
IN 1974 OUR GROUP BROUGHT SUIT IN FEDERAL COURT AGAINST THE ENVIRONMENTAL
PROTECTION AGENCY ASKING THAT AN ENVIRONMENTAL IMPACT STATEMENT BE PREPARED ON THE
HORSEPEN PROJECT AS REQUIRED BY THE NATIONAL ENVIRONMENTAL POLICY ACT. NOW THE
ENVIRONMENTAL IMPACT STATEMENT HAS BEEN PREPARED, AND THE RADIAN CORPORATION HAS
made several recommendations to epa which we find highly significant, most interes-
ting OF ALL IS THE RECOMMENDATION AGAINST FUNDING THE HORSEPEN PROJECT WITHOUT
(AND I QUOTE) " A MORE DETAILED LONG-TERM STUDY OF INDUCED IMPACTS TO LAKE BRANDT."
A COPY OF THESE RECOMMENDATIONS IS ATTACHED,SINCE IT DOES NOT APPEAR IN THE DRAFT
ENVIRONMENTAL IMPACT STATEMENT.
A FEW MONTHS AGO WE WERE LOOKING FAVORABLY UPON THE SELECTION OF THE PROPOSED
ACTION ALTERNATIVE (2-E). IT SEEMED TO US TO BE A REASONABLE COMPROMISE SINCE WE
DO ACKNOWLEDGE A NEED FOR PROVIDING SERVICE FOR THE EXISTING INDUSTRIAL WASTEWATER
IN THE AIRPORT AREA, AND THE PIPE SIZES IN THE RESIDENTIAL PART OF THE BASIN WERE
PROJECTED TO BE QUITE SMALL. HOWEVER, SINCE THAT TIME THE CITY AND COUNTY HAVE
CLAIMED THAT RADIAN'S CALCULATIONS ARE IN ERROR, AND THAT A PIPE PROJECTED TO BE
12 INCHES IN DIAMETER REALLY NEEDS TO BE 27 INCHES IN DIAMETER. THIS WOULD PROVIDE
A FIVE FOLD INCREASE IN THE CARRYING CAPACITY OF THE PIPE. WHILE WE ACKNOWLEDGE
That small errors in projecting pipe sizes could occur at this stage of the process ,
AN ERROR of THIS MAGNITUDE SIMPLY DEFIES BELIEF.
-------
Environmental Action Coalition page 2
THESE RECENT ACTIONS ON THE PART OF THE CITY AND COUNTY HAVE CAUSED US TO RECONSIDER
OUR SUPPORT FOR ALTERNATIVE 2-E, AND WE NOW FEEL THAT THE BEST ALTERNATIVE IS
THE MODIFIED NO-ACTION CONFIGURATION WHICH WOULD SIMPLY PROVIDE A NEW LINE FOR
ROUTING THE INDUSTRIAL WASTEWATER FROM THE AIRPORT AREA TO THE NEW METRO PLANT
BY WAY OF SOUTH BUFFALO. NORMAL GROWTH COULD PROCEED IN THE RESIDENTIAL PART OF
THE BASIN ON SEPTIC TANKS INSTALLED UNDER MORE STRINGENT REGULATIONS.
WE FOUND THE SUGGESTIONS FOR MITIGATING MEASURES DESCRIBED IN CHAPTER 6 OF
THE DRAFT E I S TO BE EXCELLENT, BUT UNFORTUNATELY THEY CARRY NO REAL WEIGHT,
SINCE THEY DEPEND ON LOCAL GOVERNMENTS FOR VOLUNTARY IMPLEMENTATION. THIS IS A
DISAPPOINTMENT TO US, SINCE LOCAL POLICY MAKERS HAVE NOT UP TO NOW EXHIBITED ANY
GREAT COMMITTMENT TO THE PRESERVATION OF WATER QUALITY OR LAND USE PLANNING.
WE HAD HOPED THAT EPA WOULD BE ABLE TO BUILD IN MORE MITIGATING MEASURES
AS "CONDITIONS OF THE GRANT." THE FACT THAT THEY DID NOT IS AN ADDITIONAL REASON
WHY WE PREFER ALTERNATIVE 6 OVER THE PROPOSED ACTION.
IF THE ALTERNATIVE SELECTED INCLUDES PIPES WHICH ARE SIZED TO PROVIDE FOR
MORE GROWTH THAN THE AMOUNT PERMITTED BY THE CLEAN WATER ACT, THEN THE ENVIRONMENTAL
ACTION COALITION WILL INITIATE LITIGATION ON THE GROUNDS THAT THIS PROJECT IS NOT
CONSISTENT WITH THE INTENT OF THAT ACT.
IN CLOSING, WE WOULD LIKE TO THANK THE ENVIRONMENTAL PROTECTION AGENCY FOR
PROVIDING SO MANY OPPORTUNITIES FOR PUBLIC INPUT IN THE PROCESS OF MAKING THIS
DECISION, WHICH IS OF VITAL IMPORTANCE TO US AS LOCAL CITIZENS.
-------
RMDBAN
CORPORATION
Recommendations have been made principally on the basis
cf water quality-related aspects. They include:
1. EPA and the State of North Carolina should
not include the proposed Horsepen Creek Inter-
ceptor in the 201 Facilities grant without a
more detailed long-term study of induced impacts
to Lake Brandt.
2. An interceptor thaj: serves existing develop-
ment only (including ..the airport)i ...should be
built to replace the inefficient, hazardous
network of pump stations, force mains., and
small collectors which now exists.
3. Future industrial development in this basin
should be discouraged.
4. The County septic tank regulations should be
strictly enforced in the initial siting and
sizine of septic tank drainage fields.
-------
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
P. 0. Box 27307, Raleigh, North Carolina 27611
Telephone (919) 755-4210
November 20, 1978
Mr. John E. Hagan III
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
We have reviewed the draft environmental impact state for Horsepen
Creek Interceptor, EPA Project No. C37036901.
Installing the Horsepen Creek Interceptor will likely encourage and
speed housing development in the watershed of Lake Brandt which is a
major source of raw water for Greensboro. Even though sewage disposal
is provided, high density population can critically effect the lake unless
zoning and other controls are initiated to protect water quality.
Soils in the watershed are Cecil, Madison, Enon, and Mecklenburg. All of
these soils erode easily and contribute large quantities of sediment
during the construction period if intensive sediment control measures
are not installed. The erosion hazard is especially high for Madison
soil. Specific measures for erosion control and for land treatment to
stabilize disturbed areas are not spelled out in the draft impact
statement. The plan should include measures to stockpile the topsoil
during construction so that it can be used for the final covering of the
disturbed areas.
The percentage of prime farmland within the watershed is low. Much of it
is occupied by housing developments.
The Soil Conservation Service assists soil and water conservation
districts in technical phases of their program. Consultant services
consistent with work priorities established by the districts are
available from the Service.
-------
Mr. John E. Hagan III
2
We appreciate the opportunity to review and comment on the draft
EIS. Please send us a copy of the final statement.
Sincerely,
Jesse L. Hicks
State Conservationist
cc:
Director, Office of Federal Activities, Environmental Protection Agency,
Room 537, West Tower, 401 M;Street, S.W., Washington, D.C, 20460
USDA Coordinator of Environmental Quality Activities, Office of the
Secretary, U.S. Department of Agriculture, Washington, D.C. 20250
R. M. Davis, Administrator, SCS, Washington, D.C.
J. V. Martin, Director, STSC, SCS, Fort Worth, Texas
S. G. Lane, Director, State Soil and Water Conservation Commission,
Raleigh, N.C.
R. E. Powell, SCS, Burlington, N.C.
H. W. Robertson, SCS, Greensboro, N.C.
-------
Statement of
Thomas E. Hubert, Chairman
Council on Community Development and Planning
Greensboro Chamber of Commerce
Presented
Monday, November 20, 1978
At An
EPA Public Hearing
Cn the Draft Environmental Impact Statement
for Wastewater Facilities in the Horsepen Creek Basin
My name is Tom Hubert. I'm Chairman of the Chamber's Council on Community
Development and Planning. The Board of Directors has charged our Council with
maintaining and improving the quality of life for all our citizens. We are proud
of the quality and integrity of our local governments including both elected officials
and staff.
We arc appalled that the Radian Corporation would submit and EPA would accept
such an incompetent document which is an expensive research paper paid for by us
tax payers. The consultants did not consider existing conditions, did not utilize
available topo maps, and did not bother to check the flow of existing lift stations.
In addition, we are very concerned that the federal government through EPA
would attempt to dictate to local governments^how to control their affairs. The innuendo
that local government is incompetent and unable to properly legislate local land
development ordinances is unfortunate to say the least.
These are not truths and we ask that EPA not make a decision based upon this
incompetent document.
Now let me express the Chamber's concern about the relationship of this project
to the community's development.
The Chamber has consistently supported the objective of providing an interceptor
sewer sufficiently large to accommodate the ultimate development of the Horsepen Creek
basin. The reasons for this position by the Chamber are several. First, the area will
continue to develop as a consequence of reasonable economic forces--a demand for housing
and industrial development in the basin. Second, a sizable investment in public and
private facilities has already been made. The investment would be wasted if reasonable
-------
- 2 -
development is not permitted. Third, the area is the watershed for Lake Brandt. The
sooner septic tanks and lift stations can be eliminated within the basin the sooner the
community will be assured of protecting one of its valuable water supply reservoirs.
Fourth, econony demands that the maximum size interceptor sewer consistent with develop-
ment objectives and environmental considerations should be constructed now.
The Chamber finds a hindrance to achieving its objective in the Draft EIS. It
appears that EPA is proposing to control the density of development within the basin.
We believe this and related land use decisions are solely the responsibility of the
appropriate local governments.
The Draft EIS suggests EPA prefers an alternative interceptor sewer which would
accommodate existing development plus a limited amount of new development. In rough
numbers this appears to convert to an interceptor sewer capable of handling the
wastewater flow generated by the 8,000 existing residents plus approximately 4,000
additional residents by the year 2000. However, this leaves over 6,000 individuals
who would have to be served by private sewer systems or be denied the opportunity to
live in the Horsepen Creek basin.
We share EPA's concern for protection of Lake Brandt. We share EPA's concern
that there be a reasonable density of development within the Horsepen Creek basin.
We share EPA's concern about the adverse effects of septic tanks upon Lake Brandt.
Consequently, we urge EPA to select an alternative which protects the water, allows a
reasonable level of development, and eliminates existing septic tanks as well as
prevents the need for future septic tanks. This would necessitate, as a minimum, an
interceptor sewer of a sufficient size to accommodate the flow anticipated from the
forecast population for the year 2000 of over 18,000 people.
Greensboro has good development because of responsible private developers and
quality public leadership. Our community's planning has b*en good. The regulation
of land use has been good. Growth will surely occur in the Horsepen Creek basin. The
question before u«. all is how we can insure the continued high quality development of
-------
- 3 -
our community while at the same time protecting Lake Brandt. We believe the
best way to do this is to get rid of the septic tanks. We need an interceptor
sewer adequate to serve the anticipated level of development proposed to be
permitted under city and county land use plans, policies and regulatory ordinances.
Thank you.
-------
COMMENTS ON HORSEPEN CHffiSK INTERCEPTOR SIS
by John R. Jezorek
611 N. Mendenhall Street
Greensboro, N.C. 27401
A decision on the Horsepen Creek Interceptor Sewer has been a long time
coming. One beneficial aspect of this slow process is that we in the County and
EPA have had time to sit back and look at the project a little more closely in
order to judge its merits. For ray part, I am just as convinced as ever that this
project will do more harm than good, i.e. the cost-benefit ratio is unfavorable.
The more we learn about the long term effects of consumption of water with low levels
of contaminants, the greater should be our resolve to do everything possible to maintain
the purity of our water supply. Unfortunately, large scale development in the basin
will work counter to that good.
Hopefully, the fact that EPA has recommended a sewer to serve existing needs
plus only modest growth means that they see the necessity for limiting growth in the
watershed, (it might be noted that the 1972 Federal Water Pollution Control Act
limits use of Federal funds to modest growth plus existing needs. This money is not
designated as a growth stimulator.) Growth limitation is the important point, how-
ever. The sewer of and by itself will not cause rapid growth in the basin. County
policy is what determines this.
Expansion of the tax-base and the now shop-worn platitude that "people want
to live out there" are not valid reasons for County policy to opt for complete basin
development. We must take the prudent approach, because if we develop heavily,
then find our water supply degraded, there is no easy remedy. Purification costs
are astronomical. However, should we limit growth, and later find an inexpensive
method of purifying our water, or that long-term effects are not as severe as now
believed, we can always develop more densly. My own position remains that the "no
action" or "modified no action" alternatives are most desirable. I can live with
the "modest growth" alternative, 2-E, if I were to see a resolve on the part of
the County to operate in this limited growth spirit. But should the County persist
in claiming a need for a bigger or a second pipe so that development can proceed
full-speed, then I cannot support this alternative. The suggestions made by
citizens groups and individuals are a good place to start in minimizing the
negative impact of development.
I recommend that the County seriously consider implementing these and other
suggestions to preserve the quality of our drinking water, and take strong measures
to steer growth to the east of the city.
-------
STATEMENT
The Board of Directors of the Greensboro Jaycees supports the develop-
ment of an adequate sewer system to serve the Greensboro-Guilford County
conmunity needs and rejects the recommendations of the EPA on economical,
philosophical and practical grounds.
First, economically, the sewer system will open land surrounding
the regional airport to commercial growth which will mean additional
jobs created and stabilized by the presence of adequate and attractive
commercial property. It should be noted that such property is not
attractive to the consuming public as residential property, primarily
due to aircraft noise levels. The former fact is important to us as
a group of five hundred young men who live and work now and for the
foreseeable future in this area. The second fact has historical proof
both here in Greensboro over the last ten years and in numerous communities
around the country.
Philosophically, the Jaycees contend that local decisions should
be made by local officials who are accountable to the local electorate.
Some direction, observation, and, if necessary, supervision should be forth-
coming from the federal level in order to meet standards; we do not feel
that this has been the rule on this issue. Nor do we feel that cm^ in-
creased involvement by the federal level of government on this specific
issue or pursuant to the establishment of future growth policies for
our community have any benefit. Our local governments have proved most
capable of developing such policy and have a track record to prove it.
Thirdly, and finally, the Greensboro Jaycees reject the EPA position
on practical grounds. We are satisfied that the projections by both
studies indicate the unsuitable qualities of Guilford County soil for
-------
widespread septic tank usage. Additionally, it appears safe to say
that the recommended twelve inch line would have difficulty serving
existing development and certainly could not serve even some small
additional development which is bound to occur. To argue that a sewer
system or lack of one is sufficient to deflect established growth patterns is
to ignore the personal, practical, economical, and, for lack of a better
word, parochial, reasons which cause a person to choose his neighborhood.
For these reasons the Greensboro Jaycees support! the development
of a sewer system in the Horsepen Creek Basin, sufficiently capable of
serving today's needs and the needs of tomorrow's growth. At the same
time we desire zoning standards which will protect the Guilford County
environment throughout the majority of the basin for residential growth
while making areas adjacent to the airport and major transportation arteries
attractive to quality industrial and commercial growth. This type of
impact statement and pre-planning is essential to the orderly and necessary
growth of our community if it is to safeguard the "quality of life" which
makes Greensboro-Guilford County such an outstanding place in which to live
and work.
More as a footnote than anything else, I might add that I believe I
am the fourth Jaycee president to make such a statement in this matter, and
in each instance, our organization has reopened our consideration of both
sides of the issue, and right or wrong, taken the very same position.
-------
Greensboro Chamber of Commerce
Post Offle# Box 3246. 217 North OrMntt 3tre«t. QrMDSboro,North Caroffnt 27402. Ttlepoont 919 275-807$
November 22, 1978
Mr. John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, N. E.
Atlanta, Georgia 30308
Re: Draft EIS Horsepen Creek Basin
Project No. C37036901
Dear Mr. Hagan:
Attached is testimony regarding the subject wastewater facilities
given by Greensboro Chamber of Commerce representatives at the
public hearing held on November 20, in Greensboro. This includes
the testimony of Chamber President Charles E. Melvin, Jr., Tom
Hubert, Chairman of the Council on Community Development and Plan-
ning, and Rhodes Corbett, Vice Chairman of the Council on Economic
Development.
We respectfully request that these statements be made part of the
permanent hearing record.
In addition, we should like to receive as soon as it is available
a transcript of the hearing.
We appreciate your continuing cooperation.
Sincerely,
. f
Allan Johnston,»M6nager
Community Development
Hov
-------
Federal Energy Regulatory Commission
REGIONAL OFFICE
730 Peachtree Street, N. E.
Atlanta, Georgia 30308
November 21, 1978
Mr. John E. Hagan III
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, NE
Atlanta, GA 30308
Dear Mr. Hagan:
This is in response to your letter dated October 5, 1978,
with attachment, requesting our comments on the Draft Environ-
mental Impact Statement for proposed Greensboro-Guilford County,
North Carolina, Horsepen Creek Interceptor, EPA Project No.
C37036901.
The Commission's principal concern in regard to develop-
ments affecting land and water resources is the possible im-
pacts of such projects on the construction and operation of
bulk electric power facilities and interstate natural gas sys-
tems .
In reviewing the DEIS, we noted nothing that should inter-
fere with any of the Commission's licensed hydroelectric proj-
ects. However, provision should be made to protect electrical
transmission lines and natural gas pipelines in the construction
We appreciate the opportunity to comment on your proposed
project.
area.
Very truly yours,
Aarne 0. Kauranen
Regional Engineer
NOV 2 2
-------
Statement by the League of Women Voters of Guilford County
November 20, 1978, Public Hearing on the Draft Environmental
iaipact Statement, Horsepen Creek Basin portion of
Greensboro Wastewater Management Plan, Project # 0370,^6901.
Mr, Chairman, members of the panel: the League of Women Voters
if grateful for this opportunity to speak once more on the
Horsepen Creek project.
The League of Women Voters of Guilford County has been involved
with the fortunes (some would say 'misfortunes'!) of the Horse-
pen Creek sewer outfall proposal since January, 1974, when we
took a stand against the project as it was then formulated
at a public hearing on the initial Environmental Assessment
Statement. The organization was sufficiently concerned with
on the Greensboro water supply
the probable negative secondary effects/of urbanization
stimulated by the presence of a sewer outfall-—in the Horsepen
Basin 6o join the Environmental Action Coalition as a plaintiff
in the August 1974 suit against the Environmental Protection
Agency, That suit, asking that an Environmental Impact State-
ment be written on this action, began a chain of events of
which this hearing is a culmination. It was, we bel^e, respon-
sible for slowing the timetable on construction of the proposed
outfall.
As a consequence some have pictured the League of Women
Voters as part of a band of obstructionists and rabble rousers
who were against motherhood and apple pie, and, more seriously,
against growth. Let me say emphatically, the League of Women
Voters does NOT endorse a "no growth" position! Indeed we
believe, as do most of those assembled here tonight, in the
growth of many things: knowledge, public participation in
-------
LWVGC Statement, DEIS Horsepen, cont.
11/20/78
2
government, economic strength, the health and well-being of all
citizens, and the improvement of our social and physical environ-
ment. But, where one good or desiralle end conflicts with
another, the League of Women Voters does contend that caution
is necessary in relation to short-term gain. When short-term
gain may jeopardize a resource without which we cannot long
survive water that is fit to drink—-then delay in this pro-
ject and any other of similar nature is essential.
Urbanization extracts a toll from the natural world, the
size of which we have only recently begun to appreciate. During
the months since the inception of this effort by the County,
more scientific data has accumulated regarding the effects on
water quality of non-point sources of pollution, especially
that associated with urban areas. More information is at hand.
regarding the deleterious effects of heavy metals and a host of
chemical compounds which are being found in city water supplies
for the first time. Water quality rnonitering techniques arc
being ei-tended to include , new substances which had not previously
been recognized as hazards to human health. The long-term debili-
tating consequences of some chemicals which accumulate in lto-ing
tissue have also been identified. Perhaps, most importantly
for Guilford County, the Commissioners have, during the last
four years, taken certain, steps which lay the ground work for a
satisfactory growth management plan. Much remains to be done,
but the stated policies of the Guilford County Board of Commis-
sioners acknowledge the need for land use planning to protect
fragile environments. An Open Space Program has been initiated.
-------
Lri7V3C Statement, DEIS Horsepen, 11/20/78, cont.
.J
A "Land Use Goals and Policies" statement has been adopted
which indicates a concern for balancing development and environ-
mental protection. Zoning ana subdivision ordinances are in
effect which should, if consistently applied, lead to a satis-
factory population density and appropriate construction -?nd
design safeguards in the Horsepen Basin. The County's septic
tank ordinance, strictly enforced, will be crutial in sustaining
satisfactory water quality as development in that area proceeds.
Many of these policies have evolved in the last four years.
For these reasons the League of Women Voters now favors
Alternative 6, Modfied Mo Action, with its provisions for
handling industrial effluent arising in the southwest portion
of the Basin and maintaining the existing collection system in
the eastern sector of the Basin. Low density residential
development will proceed within the statutory guides described
above. As suggested in the excellent section of the DEIS on
'•Mitigating Measures", a system for handling storm water run-off
should be instituted and the water quality tnonitering system
e-pandec. The inclusion of the Gounty in Morth Carolina's
Wastewater Management (208) Plan as indicated in Secretary Lee's
letter of 6/23/78 to Mr. White, Region IV, EPa Director, will
also provide guidance to several governmental units facing
development in watersheds. This problem is certainly not unique
to the Greensboro water supply lakes.
Finally since tne inception of the Horsepen Creek project
action has been taken to extenu sewer service to the northeast
of Greensboro. More dense development in this area made possible
by the availability of sewer lines will relieve soinev^hat the
-------
LUV6C Statement, DEIS Horsepen, 11/20/78, cont
pressures for growth to the northwest. In sum the League of
Women Voters believes that the knowledge accumulated and the
actions taken by County Government during the past four years
have increased the likelihood that we may proceed with
managed growth in the Horsepen Creek Basin and not, in the
process, "kill the goose that laid the golden egg" by irre-
versibly polluting our water supply.
\_smujw~
ItfXqXi erf Vefcrr o-f^TiwlfertiC.
ppfl DwyL CdtkjstU Dr,
Q>cw^ kort>) /V.C nicR
-------
Comment on &nv1ronmenta1 Impact Statement . Greensboro-
As citizens we are grateful to the EPA for the
studies necessary to comp'lsue this particular Environmental
Impact Statement, for it points out the interrelationships
between water quality and urbanizing lands adjacent to water
reservoirs.
'^hls document plainly states that it is not possible
to have a future population of 18,000 in the Horsepen Creek
Basin without deterioration of the Lake Brandt reservoir.
However, considerable space in the document was given to
measures which c& be taken to lessen the impact of urbaniza-
tion on the water quality of Lake Brandt.
^here are many adverse effects of increased development
in the Horsepen Creek Basin on Lake Brandt, '-i-he lake will
have a heavier load of metals and phorphorus. Ahe increased
water run-off from driveways, highways, and yards will bring
more sediment into the lake and more diverse pollutants. As
more organic materials wash into the lake problems of odor and
taste will occur.
*>ut this deterioration in water quality can be lessened
by instituting certain preventive measures as outlined in this
draft for the Environmental Impact Statement.
first, a water monitoring program for Horsepen ^reek
and Lake Brandt must begin, ^uch a monitoring system would
give early warning of problem areas where pollutants would be
entering the stream and allow preventive measures to be taken.
^uilford County- Horsepen Creek Interceptor
-------
2
Guilford County has nor regulations regarding storm
water management* Storm water regulations are needed to
lessen the pollutant loads Into the reservoir by slowing
down the run-off and allowin^filtration into the ground.
Strict enforcement of the septic tank ordinances will
see that lands which do not percolate properly are denied
permits and that peptic tankds are properly located and in-
stalled.
*hen overflows of sanitary sewage occurs a health
hazard exists. *ith the Horsepen Creek Sewer in the water
shed future tie-im to the interceptor must not be allowed
to exceed the capacity of the design, r±his must require
legal restrictions.
xhis document makes reference many times to the
necessity for good land use controls in areas which are
becoming urbanized. *e commend our uuilford County Com-
missioners and the Planning Bepartmnet for tfrvjelr policy
guidelines under the title "Land Use Goals and Policies".
Ahls publication sets forth excellent goals, but to imple-
ment these goals requires both adequate staff and money.
Presently, the uullford bounty Planning Staff is
lacking personnel in several top positions. Ahis shortage
©^professional staff Jeopardized the adequate supervision
and coordination of planning functions, but more iaportantly,
a shortage in staff meafns a lack of time for planning for
future land development.
-------
3
Under uuilford bounty's Open Space Program It is
most important that monies continue to be appropriated for
the environmentally sensitive areas, ^ome of these areas
will be in the watersheds and their careful management will
contribute to the maintainence of good quality water.
At\^J.s draft for the Environmental Impact Statement
for the Horsepen Creek Interceptoi/clearly states that
adequate land use controle^kre essential for the develop-
ment of any alternative which is selected for the develop-
s C/UerrtfJ-fv £.-¦£
ment of the Horsepen '-reek Basin, e^^/j , ,, . , . w
r 4f/c>c<> t y»proo emenr* t » &L
Again, we thank the EPA for this document and the
5 > /4nr f-t ct~r,
mitigating measures outlined for protecting the Lake
-------
GUILFORD COUNTY
SOIL & WATER CONSERVATION DISTRICT
rorrorpicK box i7««
SMINUORO, NONTH CAROLINA 27402
T«L«PHONl. 3 7 b-5400
= OUR SOIL * OUR STRENGTH
January 18, 1979
Mr. John Hagen III
Chief EIS Branch
345 Courtland St., N. E.
Atlanta, Ga. 30308
Dear Mr. Hagen:
As a newly elected Guilford District Soil and Water Supervisor
(taking office December 4, 1978) I have been reviewing the subject
EIS.
I have previously communicated with Mr. Robert Cooper, (letter
enclosed) pertaining to this matter, and forwarded the documents
mentioned in my letter.
I note on the draft of Nov. 20, 1978 that comments are to be
forwarded to your attention, therefore this letter addressed
to you.
The official expression of the Guilford Soil and Water Conservat-
ion District are found in:
Long Range Program Guilford Soil & Water Conservation
District, copy enclosed.
2* Annual plan of the Guilford County Soil and Water Conservation
District. Since I am the only new Supervisor on the board
(replacing Mr. Bowman). I agree to the official program
signed by all Supervisors on March 3, 1976, copy enclosed,
and make the official position of March 3, 1976 unanimous.
The other contents of this letter are the sole opinions and
judgement of the writer as elected Soil and Water Supervisor,
ai*d as a practicing engineer with over 25 years experience in
water supply, and water disposal.
Our comments are as follows:
1* We are unable to locate the documents and applications to be
submitted for our review, as required by PL89-754,80 stat.
1261, 42 U.S.C. 3334 by Guilford County. As a result the
official position of the Guilford Soil and Water Conservation
District has not been included anywhere in the EIS.
Re: EIS Horsepen Creek/
Greensboro Reservoir Watershed
O^FIcr innr.Au. »im COUNTY AGRICULTURAL CENTER. 330» BURLINGTON ROAD
-------
Page 2
letter Hal B. Lewis
Jan. 18, 1979
2. Page 1 of the 20 Nov 1978, EIS
A. Construct a treating plant at the Albert Pick ( by private
funds, tertiary design) and discharge to the Deep River Basin,
which is only a few hundred feet from the Albert Pick.
B. The erosion and sedimentation control plan should be submitted to
the Guilford District Soil and Water Supervisors as required by
N.C. Statute 139 as amended and to the Sedimentation Control Act
enacted by the N.C. Legislature.
3. Page 3 of the Nov.20,1978 " Recommendations".
A. Our district is engaged on a working 208 plan.
B. The City /County oppose a run off control ordinance.
C. No enforcement of county sub-division ordinances have been ,nor
will be made due to "politics".
D. No legal restrictions will be made on future tie-ins beyond
sewer capacity. The past history of delibrate over-loading by
sewercapacity in order to cry "wolf" for more funds and more
sewer lines will again be initiated.
E. Guilford County has no effective tank ordinance and does not want
an effective ordinance passed.
F. The N.C. State Association of Soil and Water Conservation Districts
recommend that prime farmland( such as in the Horsepen Creek
Watershed) be purchased as public preserves such as State Parks and
the National Forest System.
G. Preservation of water quality Is the sole mandate of the Guilford
District Soil and Water Conservation Supervisors ,as per N.C.
General Statute 139, as amended.
Our comments on the Draft EIS of Aug,25th,1978 are as follows;
The Guilford District of Soil and Water Supervisors did not have in-
put into this draft,per N.C. 139 , and PL 89-754,80 stat. 1261,42
U.S.C. 3334.
2. Page xi. No mention is made of the amount of ground water available
in Horsepen Creek watershed, nor the amount that will be withdrawn due
to increase in populations.
North Carolina General Statutes allow only one house per 40,000 sq.ft.
without sewer ,( thus only one well). With sewers no restrictions are
made and builders place 3 houses on 40,000 with 3 wells. Many studies
have been made, including the Durham report, that this type of growth
deletes the water table at a rapid rate. I estimate the water table to
be depleted within 6 years if more growth takes place without additional
water supplies being available to the area. The depletion of the water
table will erase Horsepen Creek as a source of supply for the Greensboro
water shed, as the water table feeds Horsepen Creek.
We take issue with the figures used as a base for the amount of water
consumed per day per person , for current and future use, 70 gallons,
thus determining the sewer size.
The nationally recognized standard of water consumption per person,per day
as per The American Water Quality Association is 50 gallons per day. This
figure is used nationally in the design of water conditioning equipment
-------
p&ge 3
letter Hal B. Lewis
Jan.19,1979
and is a more realistic figure than the 70 gallons per day or the figure
of 110 gallons per day used by Guilford County.
We therefore suggest that all sewer lines be reduced by 40 percent.
We appreciate your consideration of this letter and respectfully recommend
that the mandate of .N.C. G.S. 139,as amended,be followed and place the
responsibility of the future of all Guilford County watersheds into the
legal framework of the State of North Carolina.
encl;
cc: John C. White
Robert Cooper
Allen Wahab, N.C. Dept.
J. Clark Ca'usey
Hal B. Lewis
Soil and Water Supervisor
-------
AREA WIDE PROJECT REVIEW
S-MMrntt from the Demonrtratfca Cities s^c Metropolitan Development Act of
Kxc<5rpM (PX. 89-754, 20 Stat. 1261, 42 U.S.C. 3334)
Coordination of Federal Aid in Metropolitan Areaa
SECTION 204. (a) All applications made alter June 30,1967, for Federal
loans or grants to assist in carrying out open-space land project# or for the
Panning or construction of hospitals, airports, libraries, water supply and
distribution facilities, sewerage facilities and waata treatment works, high-
ways, transportation facilities, and water developmeat a*d Im4 c®»*W***®a
projects within any metropofilaa area shall be adbadkted lor review—
(1) tt> «y area wide agency which is designated to perform metro-
politan or regional planning for the area within which tin assist aane is
to be used, and which is, to die greatest practicable extent, oo&poaisd of or
responsible to die elected officials of a unit ft areawide govermawt or
of the units of general local government within whose jurisdiction muk
agency is authorized to engage in such planning, and
(2) if made by a special purpose unit ef local government, to the
unit or units of general local government with authority to operate In
the area within which the project is to be located,
(b) (1) Except as provided in paragraph {2) «f this subsection, each
application shall be accompanied (A) by the comments and recommenda-
tions with respect to the project involved by die areawide agency and
governing bodies of the units of general local government to which the
application has been submitted for review, and (B) by a statement by &e
applicant that such comments and recommendations have been considend
prior to formal submission of the application. Such comments shall include
information concerning the extent to which the project is consistent with
comprehensive planning developed or in the process of development for th«
metropolitan area or the unit of general local government, as the case may
be, and the extent to which such project contributes to the fulfillment of
such planning. The comments and recommendations and the statement
referred to in this paragraph .mail, except in the case referred to in para-
graph (2) of ihis subsection, : reviewed by the agency of the Federal
Government to which such application is submitted for the sole purpose of
assisting it in determining whether the a^plicatien b ia secordsno. with
the provisions of Federal law which govern the making of ihe loans or grants.
(2) An application for a FedOral loan or grant need not be.accom-
panied by the comments and recommendations and the statements referred
to in paragraph (1) of this subsection if the applicant certifies t£at a
plan or description of the project, meeting the requirements of such rules
and regulations as may be prescribed under subsection (c), or such appli-
114
-------
DETERMINE WATER USAGE
APARTMENTS AND TRAILER PARKS
TABLE 3 Finures are bawd on SO qnllont per parson per day, 3 peopl* per unit,
each unit containing a bathroom, kitchen link, and laundry tub.
Number of units
Total water usage (except sprinkling)
5
10
15
30
40
SO
750
1,600
2,250
3,000
4,800
6,000
7,500
Peak GPM with flush valves
Peak GPM with flush tanks
50
23
68
35
80
45
90
53
109
67
128
80
145
93
Toilets by-passed (gal/day)
(Estimate 30 gal/person)
450
900
1,350
1,800
2,700
3,600
4,500
Toilets by-passed (flow GPM)
20
32
42
19
61
73
84
Hot water only (gal/day)
(Estimate 20 gal/person)
300
600
900
1,200
1,800
2,400
3,000
Hot water only (flow GPM)
13
23
31
38
46
54
62
MOTELS
Figure$ are based on 40 gSllons par parson per day. 2-1/2 people per unit,
TABLE 4 each un,t containing a bathroom group. Estimate watar usage for restaurant
or cocktail bar facilities separately.
Number of units
Total water usage (gal/day)
10
20
30
40
7R
1Q0
125
1KO
1,000
2,000
3,000
4,000
5,000
7,500
10,000
12,600
16,000
Peak GPM with flush valves
Peak GPM with flush tanks
68
28
90
43
109
55
128
65
146
75
180
105
210
130
240
152
270
172
| Toilets by-passed (gal/day)
] (Estimate 25 gal/person)
625
1,250
1,875
2,500
3,125
4,690
6,250
7,815
9,375
j Toilets by-passed (flow GPM)
25
38
48
58
87
84
105
125
145
Hot water only (gal/day)
i (Estimate 16 gal/person)
400
800
1,200
1,600
2,000
3,000
4,000
5.000
6,000
j How water only (flow GPM)
17
28
36
43
48
62
73
85
96
^BLE 5 Because of the wide variation in number and type of fixtures used for the following establish-
ments, water usage figures only are given. To determine flow In GPM, saa fixture unit. Table 1.
SCHOOLS
With cafeteria and showers estimate 25 gel/day per student (total wetar usaga), or estimate to gal/day
per student (hot
-------
GUILFORD COUNTY
SOIL & WATER CONSERVATION DISTRICT
povromci box
OHINnOKO. NORTH CAMOLINA 17401
= OVI SOIL * OUR STUM
January 18, 1}
TILKPHONC- 37b-3'»00
Mr. Owen Braughler, Head
Division of Environmental Health
Guilford County Health Department
301 North Eugene Street
Greensboro, N. C.
Dear Mr. Braughler:
A major area of study planned for 1979 by the North Carolina Soil
and Water Conservation District Research Committee, of which I am
a member, is that of sewage and wastewater treatment and disposal
methods used throughout the districts.
As disposal of wastes by means of septic tank.systems is an integral
part of this area of study, we need to have pertinent data contained
in the field records of the required "percolation tests" conducted b
the Sanitarians.
We need this information to assess: (1) the extent to which septic
tank disposal systems may be used in the district realted to types
of soils; (2) the indicated degree of effectiveness of septic tank
disposal systems previously approved and now in use; (3) the prov?
ions for approval of septic tank system installations when percol
ion rates nearly meet the minimum standard rate (1 inch per 60 mj
utes). The provisions are set by the inspecting Sanitarians who,
under particular conditions, are permitted to allow modification
in the disposal system structure.
On a separate page, attached, I have listed the specific items of
information we wish to obtain. You may note that this is basic
field data, i.e., the-^ates of percolation corresponding to the
holes tested. Bee ust the work that may be involved in collect-
ing this data, work which may overburden your present employees, I
propose that I and/or an assistant undertake the task. I am familiar;
with the percolation test procedures and required documents for the
Sanitarians use and registration of approval.
I am sure that you recognize both the importance and urgency- of the
work to soil and water conservation planning in' the district, and
we seek your full cooperation. To aid my scheduling of time to
obtain this information, may I have your response at the earliest
opportunity?
Sincerely yours,
Hal B. Lewis
cc: Dr. J. L. Holliday
Dr. Van Jenkins
-------
GUILFORD COUNTY
SOIL & WATER CONSERVATION DISTRICT
fovt ofpici aox *7t*
ORSKNMOKO, NOWTH CAROLINA I74CI
5 OUR SOtt. * OM STKMTN
TELEPHONE. 37b»3<»00
Page 2 : attachement to Hal Lewis letter of 1/18/79
Specific Information Requested from Sanitarians' Percolation Test
Records For the peridd 1960 to present date
~
1. Locations of percolation test holes (from plat maps or other
graphic means and/or by narrative descriptions)
2. Rates of percolation corresponding to each test hole
3. Types of soil in which percolation test hole's were dug, if
known
4. Dates upon which percolation tests were conducted, corresponding
to each test (2 or 3 holes to establish one filter field)
5. The final evaluation of the suitability of each lot for the
installation and use of a septic tank sewage disposal system
together with Sanitarian's requirements to gain approval
(discretionary determinations) where marginal percolation
rates occurred.
OFFICE LOCATION: GUILFORD COUNTY AGRICULTURAL CENTER. 3309 BURUNGTON ROAD
-------
GUILFORD COUNTY
SOIL & WATER CONSERVATION DISTRICT
poarorriCB aox
BOMO. MONTH CAROLINA 17*01
§ 0U| SOU * QUI STItNCTN
TBklFHONI. 37tt-b400
January 18, 1979
Mr. Larry Harvell
Division of Environmental Services
301 N. Eugene St. - Rm P-17
Greensboro, N. C. 27402
Dear Mr. Harvell:
In reviewing the City-County Water-Sewer Agreement I note that
certain areas were agreed to be serviced, but the areas were not
listed in my copy of the agreement.
As a member of the North Carolina Association of Soil and Water
Conservation District research committee, doing research on 208
planning, I need this information, i.e. what specific areas are
covered in the agreement of 26th May 1968?
Thank you for your cooperation.
Yours trulv.
Hal B. Lewis
OFFICE LOCATION: QUILFORO COUNTY AGRICULTURAL CENTER. ISO* BURLINGTON ROAO
-------
GUILFORD COUNTY
SOIL & WATER CONSERVATION DISTRICT
POST OFFICE BO* I7M
«l«KNMORO. NOMTM CAMOIINA S740*
TILtPMONt. 37t)-b400
SOW SOIL * OUI STRU6TH
January 18, 1979
Dr. Van-Jenkins, County Soil Scientist
Soil Scientist Office
Guilford County Court House
Government Center
Greensboro, N. C.
Dear-Dr. Jenkins:
The State Soil and Water Conservation District Research Committee,
with whom you as a former S.C.S. employee may be familiar, has
proposed to study sewage treatment and disposal methods in the
various districts.
You, undoubtedly, recognize the significance of this kind of
study of the use and possible use of septic tank disposal systems
to the prudent use of limited soil and water resources within a
district area.
To our knowledge, no systematic procedure has been undertaken
to relate actual percolation tests conducted by County Sanitarians
to types of soil found in the county. Guilford County, I under-
stand, has a tremendous advantage over many other counties in that
it has been entirely mapped and that at least one-half of the in-
formation to discover this relationship is available. Again, I'm
sure you appreciate the practical significance of relating measured
percolation to known soils—any defineable pattern indicating the
capabilities of the various soil types to serve as safe filter
fields would be a decided aid in soil and water convervation
planning in the county.
It is very possible that you may have taken some initial steps in
the direction of this kind of study, if so, we would be grateful
to have the results of your work as well as any other information
or advice you might offer to help direct our efforts.
Sincerely yours,
Hal B. Lewis
orncc LOCATION! OUILFOHD COUNTY AGRICULTURAL. CENTER. S40* SURUNOTON ROAD
-------
GUILFORD COUNTY
SOIL & WATER CONSERVATION DISTRICT
porr oMiea »ox
OMINIWHO, NOIIfX CA»OLINA IT *01
TKLKPHONI 376-5^00
s OUI SOU * Mil STR1MTK
January 18, 1979
Mr. Larry Harvell
Division of Environmental Services
301 N. Eugene St. - Room P17
Greensboro, N. C. 27402
Dear Mr. Harvell:
The North Carolina State Association of Soil and Water District
Research Committee, of which I am a member, are doing research
on 208 plans.
Please advise under which conditions:
1. Public Line Construction
2. Publich Health Neccessity
3. Privately Financed Construction
Were the following projects initiated;
1. Extending water and sewer to Reedy Fork
2. Extending water and sewer to Naval Reserve Center
3. Extending water and sewer to Airport Industrial Park
4. Extending sewer to Korsepen Creek Watershed.
Thank you for an early reply.
Yours truly,
Hal B. Lewis
Soil and Water Conservation District Supervisor
Of PICK LOCATION: GUILFORD COUNTY AGRICULTURAL. CCNTKR. SSOS SURUNOTON ROAD
-------
GUILFORD COUNTY
SOIL & WATER CONSERVATION DISTRICT
POVTOPriCK BOX I7««
aft*(N«IO*0. NOMTM CAHOLINA 17401
TILtPMOMB 178-b<«00
= OUR soil * 0U« STKJKTH
January 4, 1979
Howard N. Lee, Secretary
North Carolina Dept. of Natural Resources
and Community Development
P.O. Box 27687
Raleigh, North Carolina 27611
Dear Secretary Lee:
As a newly-elected member of the Guilford Soil & Water Conservation
District Board of Supervisors, I have been'reviewing the September
1978 draft of the Environmental Impact Statement of the Horsepen
Creek Interceptor Project, the proposed project to extend sewer
lines into the water shed of Greensboro's water supply reservoirs.
I have noted your letter of June 28, 1978 to Mr. John White, EPA
Region IV Director entered as the final page of the draft.
Because the Soil and Water Conservation District Supervisors have been
mandated to protect the watersheds within their respective districts,
I surmise that an amiable, cooperative relationship must be estab-
lished between the Boards of Supervisors and your department to
enable the Supervisors to fulfill their responsibilities successfully.
Consequently, to aid my understanding of your position concerning
the sewering of the Horsepen Creek/Greensboro reservoir watershed
in the Guilford County Soil and Water Conservation District, I
need more detailed information than given in your June 28 letter.
I refer particularly to the objection you* have expressed to the
alternative selected by the EPA, described in the draft, and'am
much interested in the specific reasons supporting your objection.
Presently, based upon the information in the draft EIS, I am con-
vinced that the EPA alternative (and safeguards suggested in the
"Mitigating Measures" section) are compatible with a sound -soil
and water conservation program as well as more nearly fulfilling
the intent of the National Environmental Policy Act; that federal
money be granted only to those projects which, principally, will
alleviate existing conditions presently threatening the health of
the established inhabitants of a given area, and not promote
projects which contrarily, pose threats to human health and safety.
I am especially interested in knowing your thoughts related to
this aspect of the proposed sewering project and, respectfully,
await your earliest reply.
Hal B. Lewis
OFFICE LOCATION: GUILFORD COUNTY AGRICULTURAL CENTER. MOI BURLINGTON ROAD
-------
GUILFORD COUNTY
SOIL & WATER CONSERVATION DISTRICT
ro«TOfPici box its*
OKHNflOKO. NORTH CAKOIIN* J7*Oi
TILIPHONI. 7 b" ')<»00
= OM SOtt * OUR STKKCTH =
January 4, 19 79
Mr. Robert Cooper
Environmenntal Protection Agency - Region IV
345 Courtland St.
Atlanta, Ga. 30308
Dear Mr. Cooper:
As a newly elected member of the Guilford District Board of
Soil and Water Supervisors, (taking office Dec. 4, 1978). I
have been reviewing the EIS Horsepen Creek Interceptor, serving
a watershed supplying drinking water to Greensboro, North Carolina.
I was astonished to learn, according to our telephone conversation,
that no input had been received from the Guilford District Board
of Soil and Water Conservation Supervisors.
As per your request for public information pertaining to this
watershed I am enclosing:
1.. A copy of North Carolina General Statute 139.
2. Long Range Program for Guilford County Soil and Water Conser-
vation District.
3. Annual Plan of the Guilford County Soil and Water Conservation
District 1978-79 fiscal year.
4. Program objectives 1978-79 North Carolina Association of Soil
and Water Conservation Districts.
We concur in all the program and objectives as expressed, or
outlined in this literature and General Statute.
A separate letter will follow, from the writer, commenting #on
the EIS, due to the time limitations we are forwarding the.
enclosed for your immediate use.
Yours trulv.
Hal B. Lewis
cc: Allen Wahab
John C. White
OFFICE LOCATION: GUILFORD COUNTY AGRICULTURAL CENTER. 3SO» BURLINGTON ROAO
-------
December 4, 1978
Mr. Bob Cooper
Environmental Protection Agency
345 Court!and Avenue
Atlanta, Georgia 30308
Dear Mr. Cooper:
Enclosed is the response of the Guilford County
Advisory Board for Environmental Quality to the
Environmental Impact Statement for the Horsepen
Creek Interceptor Sewer Project. The statement was
presented at the Environmental Protection Agency's
public hearing in Greensboro on November 20, 1978.
For the past several years, one of the Advisory
Board's most important and ever-increasing concerns
has been water quality and its relationship to
urbanization. This pervasive concern over water
quality was the motivation behind our current re-
study of the issue of the sewer line.
The Guilford County Advisory Board feels that
Alternative 5, the no growth alternative, offers the
best long-term protection of water quality, and we
encourage that Alternative 5 be substituted for Al-
ternative 2-E as recommended in the Environmental
Impact Statement.
Advisory Board for Environmental Quality
PEL:nh
cc: Mr. Mark Oakman
Mr. Lee Wilson
-------
November 20, 1978
THE RESPONSE OF THE
GUILFORD COUNTY ADVISORY BOARD FOR
ENVIRONMENTAL QUALITY
TO THE
ENVIRONMENTAL IMPACT STATEMENT FOR
THE HORSEPEN CREEK INTERCEPTOR PROJECT
Ever since its inception in 1972, the Guilford County Advisory Board
for Environmental Quality has considered that the problems associated with
water are the most serious and urgent environmental issues facing Guilford
County now and in the future. Our Board has ranked as a priority concern
both water quality and quantity, and this deep concern has been manifested
in many different forms in the past 6 years. Since the Horsepen Creek
Interceptor Project directly impinges on water quality, our Board has taken
an unusual amount of interest in this project and Its EIS; Board members
have brought considerable professional insights to bear on the many parameters
of the entire project.
The Advisory Board is unswerving in its diligent pursuit of maintaining
and even enhancing water quality for all our citizens. This Board has never
been against growth or development so long as those factors did not signifi-
cantly contribute to environmental degradation. But we are resolved in our
conviction that water quality degradation is directly proportional to urban
and suburban densities in the watershed. We believe that spreading urbanization
-------
- 2 -
adds numerous exotic (rare, unusual) chemicals and compounds to water
supplies in very subtle amounts. Further, we are convinced of the real
possibilities of very severe human conditions that will result from the
protracted domestic use of water which is impounded immediately downstream
from large suburban areas. There is a growing body of scientific studies
to support and validate these concerns. The specter of carcinogenic,
pathogenic, teratogenic, and mutagenic effects induced by deteriorating
water supplies is a bleak, grim prospect for the future. We believe that
population densities in the watershed must be kept low in order to preserve
an acceptable degree of water quality.
The Horsepen Creek project is a classic example of the potentiality
of completely degrading a municipal water supply by developing suburban
areas in the watershed. The installation of a sewer interceptor line in
the basin will certainly foster more intense development. More people will
bring increased amounts of a variety of exotic chemical compounds and metals
that already threaten to destroy irreversibly water quality in all the lakes
downstream. Therefore the Guilford County Advisory Board for Environmental
Quality feels that Alternative 5, the no action alternative, offers the best
long-term protection of w< ter quality, and we encourage that Alternative 5
be substituted for Alternative 2-E as recommended in the EIS.
The Advisory Board has, over the past 20 months, consistently advocated
to the Board of County Commissioners that population densities must be kept
comparatively low in this fragile watershed. We have strongly urged the
Commissioners to support measures which will minimize growth in the basin and
which will retard runoff into the impoundment. We will continue to advocate
for mitigating conditions which will reduce the chances for the water supply
to be damaged further. But the influence of the Advisory Board to institute
protective measures is limited, and we need any additional help to regulate
density in this watershed; Alternative 5 will do precisely that.
-------
SIERRA CLUB £3 Joseph LeConte Chapter
¦ ¦ - T° explore, enjoy and preserve the nation's forests, waters, wildlife and wilderness . ..
itmWr
Horsepen Creek Interceptor, Greensboro, N. C.
Statement of Piedmont Plateau Group - Sierra Club
November 20, 1978
Given by Pat Lutz, Chairperson
The Sierra Club has been on record as opposing this interceptor line through
the Horsepen Creek basin since it's initial proposal. After the EIS was published,
we felt that our concerns and objections were confirmed. In fact, the water qual-
ity is rapidly deteriorating with the amount of development presently found in the
basin. The effects of septic tanks, once thought to be the principal source of
pollution in the basin, have been shown to be minimal. Surprisingly, the principal
sources of pollution have been due to the urbanization process itself. Lake Brandt
is a precariously balanced eco-system at this time with very little ability to ab-
sorb additional pollutants. Any change in the present land use patterns will destroy
this balance - bringing on eutrophication of the lake and thereby making it unusable
as a drinking water source. The pollutants in this case are the nitrogen and phos-
phorus levels. The concentrations of these chemicals will be increased as the basin
becomes urbanized. Eutrophication is being held in check now by sedimentation
from agricultural lands, and while sedimentation itself is undesirable, without
it Lake Brandt would be "dead" today.
The EIS also found that the concentrations of lead in Lake Brandt exceeded
the federal safety regulations for public drinking water supplies. These lead
concentrations are a direct result of urbanization and the transportation systems
that must accompany it. Lead is a cumulative poison, and long-term exposure,
aven to moderate concentrations, can cause chronic illnesses and perhaps death.
The concentrations in our water supply are already dangerous and further urbaniza-
tion will bring more of these exotic chemicals into the water supply. To ignore
this concept, which is so clearly stated in the EIS, is almost criminal, and the
effects will be felt by citizens for years to come. 'j
We have highlighted only a few of the problems that concern us about this pro-
posal, but we feel that these illustrate our position. The lasting effects of a
mistake at this juncture in time make this proposal something more than a mere
sewer interceptor line, and for that reason we recommend that Alternative #5 or 6
be accepted. We would also urge the EPA to accept the data reflected in the EIS
in their decision-making process. This data, gathered by an unbiased study group
with no contractural agreements in Guilford County, would seem to be the most
credible. Our water supply problems are already legendary; we must not destroy what
we have. The Sierra Club has operated for mani) years with a motto that is very
appropriate for this issue - "Not blind opposition to progress, but opposition to
blind progress."
Ms.. Pat Lutz
5408 Ainsworth Drive
Greensboro, N. C. 27410
-------
OR. DOUGLAS P. MAGANN III, SUPERINTENDENT
GUILFORD COUNTY SCHOOL aYSTEM
1ZO FRANKLIN BOULEVARD
P.O. DRAWER B-2
GREENSBORO, NC 27402
272-D191 882-1822
December 4, 1978
Mr. John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, N. E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
I am writing to ydu with regard to ongoing deliberations
about the proposed Horsepen Creek Interceptor Sewer in the Northwest
section of Guilford County. Although public schools must serve the
public wherever that public resides, certain long range decisions were
made prior to my arrival in Guilford County and I think you should be
aware of them before you reach a final decision.
Several school complexes were constructed in the western
and northwestern areas during the late 1960's and early 1970's to
accomodate projected residential populations. The site locations were
chosen on the basis of these projections and millions of tax dollars
were expended. At the time the decisions were made, the planners used
the best information available. I doubt that anyone anticipated the
questions involved in the present debate.
Two school complexes "bracket" the Horsepen Creek area
and were intented to serve a substantial population projected for that
area. I am concerned that, if development is severely restricted as
a result of inadequate wastewater removal facilities, radical rezoning
will become necessary and pupil transportation costs over time will
be astronomical. Tbese two negative results will be necessary to make
efficient use of existing facilities.
I am an advocate of rational land use and consider myself
an environmentalist. I do not wish to support a decision that will
have catastrophic environmental results. Based on my understanding
of the effects of the proposed sewer lines, I cannot but conclude that
rational use of the land area would be fostered by adequate lines.
EDUCATIONAL EXCELLENCE
-------
Mr. John E. Haganf III
Page 2
December 4, 1978
Thank you for the opportunity to share this information
with you. If I can be of future assistance to you, please do not
hesitate to contact me.
cc: Allen Johnston
W. B. McLeod
J. R. Sinclair
I. H. Black
C. Howard Cross
T. G. Madison
Sincerely,
-------
Statement of
Charles E. Melvin, Jr., President
Greensboro Chamber of Commerce
Presented
Monday, November 20, 1978
At An
EPA Public Hearing
On the Draft Environmental Impact Statement
for Wastewater Facilities in the Horsepen Creek Basin
I am Charles Melvin, President of the Greensboro Chamber of Commerce. The
Chamber is a voluntary association of over 1800 civic and business leaders concerned
with the appropriate growth and development of the Greensboro area.
We welcome EPA representatives to our community this evening. The Chamber
appreciates your efforts to insure protection of the environment and achieve wise
use of federal financial resources.
We understand the purpose of tonight's hearing is for EPA to receive comments
on the Draft Environmental Impact Statement for the Horsepen Creek basin. We under-
stand that there are questions of fact yet to be resolved between EPA and the County.
These questions of fact relate primarily to existing and anticipated sewage flow and
engineering factors related to design of the collection system. We urge EPA to meet
with the County to resolve such questions.
The Chamber has worked through the years in a cooperative relationship with
Guilford County and the City of Greensboro. We believe our community has benefited
from a close working relationship among local, state and federal governments. The
Chamber urges that EPA work closely with the County to achieve a wastewater collection
system adequate and appropriate for the level of development forecasted to occur.
The Chamber is concerned about wastewater facilities in the Horsepen Creek basin
for several reasons. First, it is the community's major growth center with significant
residential development. Second, as the center for industrial growth, it is an area
which affords residents of our community excellent employment opportunities. Third,
it is a watershed for our community's water supply. We are vitally interested in the
protection of that supply. Fourth, because of the extensive urban development which
has occurred on septic tanks, we are anxious to see the completion of public waste-
water collection facilities.
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- 2 -
The Chamber urges construction of an interceptor sewer adequate to serve the
ultimate development of the basin.
If EPA does not concur in the Chamber's position, we believe the public interest
demands that a system consistent with optimum community development and a meaningful
cost-benefit evaluation be constructed. The Chamber wants to eliminate additional
delays. Accordingly, the Chamber will support an interceptor sewer judged by the
County, based upon sound engineering studies, to be appropriate for existing and
future development of the Horsepen Creek basin.
Thank you.
-------
~tr/v>
ON HORSEPEN CREEK INTERCEPTOR
STATEMENT BY MAYOR JIM MELVIN
ENVIRONMENTAL IMPACT HEARING
November 20, 19 78
Ladies § Gentlemen,
Hopefully this is the last hearing that will be necessary in
order to make pollution abatement in Guilford County a reality.
We have finally decided on a site for the Metro Plant. We have
decided that an outfall in Horsepen Creek is desirable and has less
adverse environmental impact than for the area to develop on septic
tanks. What we will be discussing tonight should be a function of
the Step II Design Phase of this project and not of the Step I Plan-
ning Phase.
We have carefully studied the draft Environmental Impact State-
ment. We are in agreement with many of the conclusions which have
been known for years.
The City of Greensboro has worked closely with Guilford County
since 1965 to provide an orderly development of a water supply and
sanitary sewer system for those in our community who happen to live
or work outside the corporate limits of the City. The agreement in
existence has been a model for others to use. It has been successful.
The intergovernmental relationship between Guilford County and Greens-
boro has been contributory in making the quality of life in this
community so good that a recent study by the University of Nebraska
has ranked us as the 5th best community in the nation in which to live.
-------
2
As previously pointed out by Chairman Campbell, regulation of
development has been controlled by zoning. Subdivision ordinances
and erosion and sedimentation control ordinances are in effect.
Stormwater Management will be a reality shortly. The County and
City now are planning for long-range water supply projects in con-
junction with State and Federal Governments. I cite these to show
what local government is^ doing to enhance the environment in which
we live in and to refute the statement in the draft EIS that a lack
of desire to mitigate secondary impacts exists within local govern-
ment. We have the tools and the will. And I might add here that
the draft EIS does recognize that mitigative measures to protect
the quality of water in Lake Brandt are already in use or proposed.
More importantly, we have the support of the people. A survey com-
pleted this month indicates that over 70% of the people feel that
the quality of life in our community has improved since they have
lived here. The survey also indicated that they are vitally inter-
ested in Environmental matters. That same study gave showed that
nearly 85% of those surveyed gave high marks to local government
regarding regulation, services and taxes. So we must be doing a
few things right.
It is fashionable to blast EPA at every opportunity, but we are
going to forego that opportunity tonight. It is our sincere feeling
that EPA got some bad advice from their consultants?^But then every-
one errors occasionally and all that we ask is that EPA not take a
concrete position on specific pipe size but rather let the engineers
design the system based upon existing condition being consistent
with the agreed upon population to be served in the year 2000.
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- 3 -
If this is done we are confident that the interests of all can be
served to the fullest extent.
would close by emphasizing three major points.
1. The engineering relating to pipe sizes is lousy. When
pipes 20 feet deep supposedly cost the same to install as an equivalent
size pipe 6 feet deep and then do not even then conform to required
state standards, then lousy is as kind as I can be. I suspect that
the main problem was that they did not know which way the sewage
flowed.
2. Controls to deal with growth in the basin and protect the
quality of the water in Lake Brandt are in place and are acknowledged
in the draft EIS.
3. The question of 208 Planning is of no concern in this
question. Where an area is not designated as a 208 area the respon-
sibility becomes one of the State, in this case North Carolina. The
plan which the County has set forth for handling the wastewater in
Horsepen Creek is not an unreasonable one. It is acceptable to the
State and the City of Greensboro wholeheartedly supports it. Thank you.
-------
nr. John S. Hagan III
Chief, "IS Branch
£PA,- Region IV
T)UK. Courtisnd street, ME
Atlanta, GA 3'^308
or?: r.r?ft of TA ^nvl ronnwnW Impact St^t.nment. Grcensboro-Cuilford County
North Carolina Horsepen Croek Interceptor. V?X Project No. C37030°01
(^leese include t>ese comments asvpart of the record of the public hearing
held on November cu, 1978 in Greensboro)
DRAFT R*wrafl5D BY: James R. Rees, Soil Scientist
Physical Environments Analysts, Inc.
loO*) Marion Street, Greensboro, N.C. 27U03
Date: 10 October 1Q78
The following comments end/or auestions are made as a response to the above
Craft T.I.S. and to facilitate presentation and reading, are divided into
"sections," aprrorriately captioned.
I. Assumpti ons of Future Porulation Density and Development of the Hn*-sepen Crsek
Because the "projected" settlement of the bssin appears tc be a rrimo ccr. tide rat ion
upon v:hich most cf the other ccnsideretions of the E.I.D. are founded, trH PSfoct
cf the environments1 impact investigation and subsequent draft rerort calls for -n
intensive analysis.
All scientists are veil aware that although the use of "assumptions" (of fact, unl<ȣ
otherwise identified) facilitates interpretive vork snd ovalustions (of whatever
phenomena is being reported), the bases for the assumptions are open and fchoulu
for critical review and questioning.
In the Quest for the factual bases for assumptions, scientists understand thet the j
of preceding reports from var'ous other sources may or msy not be reliable ana/or ro
inent evidence to substantiate assumptions made in following; reports. Thi:; pricr
informetion, itself, is subject to verification either by intensive examination to
3
"estimate" its reliability, or^better, by b&sic research to corroborate the earlier
findings and conclusions reported. This ia Jio,thin<; more, of course, thsr. a ieccript
ion of an important pert of objective, scientific enquiry.
-------
Ttevier of ^IS: Horsepen Cre ->k Interceptor Project - James Rees 2
In this verification rroness, re-^xnmination of the exist inr. phvrnr 1
materials and forces of the environment causes little difficulty in terms
of ssc^rtsining the reliability of the data of other earlier reports. Ex-
isting physical materials and forces can be observed and measured and reason-
able disparities between tv:o or more separate investigations (due to normal
change) can be accented. However, projections to predict future condition?>
even of nhys^al conditions, by meens of trends, patterns, analogs produce,
at besit, tenuous evidence to support assumptions. This uncertajnt.v is r^d-
icfilly compounded when persons attempt to foresee what wilful human individ-
uals, resronding to fluctuating economic pressures and personal desires,
will do, i.e., where populations will move end establish themselves.
V/hen demographic statistics are derived to project settlement in defined
Areas (usinr; past established statistics to ascertain trends), official
decisionmakers (and others) are prone, erroneously, to accept the conclus-
ions as fact. Once the "fact" is assumed, it is used by planners (and others)
as a point of argument for the need to provide shelters for the "increased"
numbers of persons, ipso fecto. in the defined area. This approach relegates
the natural suitability of the defined area for habitations to a secondary
place in importance. It is, essentially, e concession to the established
practices that are
practices of environmental resource use / getting entire populations
into trouble, ecological and economic trouble. The motivating view behind
the establifai.eu practices of use is that natural forces can be overridden by
man at his will; that alleviation (correction) of certain adverse reactions
to incompatible use can be treated conseouently as ? secondary matter. Tc
state it succinctly, the use of demographic projections encourages the im-
pulse to place undue emphasis upon housing numbers of persons, who may or
may not be nresent at a future time, in natural areas physically unsuited
-------
Review of ^IS; Horsenen Cro -.k Interceptor Project - James Recs
for this type of land use.
If the tnt*nt of the National Snvironmental Policy Act is «»*U. and im-
portance i. attached to settling humans in environments th»t can accomodate
the facilities of hawing developments without radical disruptions (environ-
ments that are safe, healthful, pleasing and where costs of establishment,
maintenance, and repair are minimal), the necessity for using dubious popul-
ation projections as a basis for developing specific areas has not been nroven.
A rearrangement in the priorities of investigation of areas proposed for devel-
opment would preclude the use Of initial demographic predictions. This converse
approach appears to b. definitely more realistic, scientifically sound, economic-
ally prudent, and ecologically safe, i.e., carefully inventory and analyze the
Physical characteristics (including biological entities) of specific areas first
and foremost. From these findings, consequently, determine the number of shelters
(density of habitation) the location can "bear" safely, healthfully, at minimum
private r.nd public costs. In essence, this permits the physical qualities of
a fiver, land area to regulate in-migration and reduces the stress upon planners
(and EPA personnel) to fit, by expensive means, the shelters needed to accomodate
a predicted number of peonle into an area that may be largely inhospitable to
t'ris use.
Specific Critdm'sm
The fonnat, data, and language of the draft SIS all demonstrate that the authors
have been cverly-rreoccupied with¦using demographic projections as fact. Numerous
"assumptions," implied as well as stated explicitly, proposed to undergird following
assertions throughout the text, reveal this clearly. Section 3.2.5.1, Demo£rfphy
and Economics contains an outright statement of th« fact, as follows:
"An underlying assumption in developing the alternatives hss been that
18,700 people will 13ve in the Horsepen Creek basin in 2000. This re-
presents a growth of 10,620 from the 1975 population of 8,080. This
growth projection is a constant in this snalysis, regardless of the alternstivi
-------
L Review of EIS: .Horseprn Creek Basin Interceptor Project -Rees Zj
References are mart- directly or by implication tc this rrojected population
statistic or "growth" figure on 10 other pages in the report: cages 22, 24,
30, 35, 37, 38, 39, 45, 101, 102. In all of this, unfortunately, no explan-
ation was included to assess the validity and reliability of this statistic,
how it was derived, from what source did the statistic come, what extrinsic
influence (for instance, energy shortages) could act between 1978 and year
2000 to radically alter the apparently "hard-and-fast" statistical conclusion.
Inasmuch as the bases for the assumptions relied upon in the RI3 investigation
anH 8s rerorted was not sufficiently explained, a full perspective of the en-
vironmental impact of the proposed severing project was not offered. Perhaps
of equsl importance is that uncertain statistical evidence is given credence
by its use by "authority," the Environmental Protection Agency, to set the
precedence in planning for other public projects affecting the environment.
To the extent that the effort to ascertain the physical characteristics and
car-abilities cf the land is weakened by the distraction of unsure porulstion
predictions as the prime consideration for development, we will continue to
suffer undesirable environmental and economic repercussions.
JJ. Effects of Roadways Uron Flew and Pollution of Horseren Creek
Section 5 1.1.2.2, Effects on Horseren Creek Flew includes the following statement:
"The STORK model (RA-R-667) results predict en increase in rcsd mileage
in the basin from the present 55 miles to 128 miles with sanitary sewer
development or lc5 miles with septic tank development."
The significance of the comraritive statistics of road mileage (between sewered
development and development cn septic tank systems) relstive to Creek flow has
not been explained. An inference csn be drawn (without this explanation) that
li.ne?l miles of roadway may affect flow characteristics more than areal dimensions
(miles x width). It seems reasonable to expect that heavier traffic attends
-------
f Review of ^IS: Hcrseren Creek Basin Interceptor Project - James Rees J5
developments of m<*her density (severed development). Consequently, it seems
likely that such development vould require wider roads (guttered reads vith storm
sevsrs even). Thus, there would be a. greater total «res of imcervious surfaces
through sewered developments to adversely affect stresm flows (and water qusli^y)
. than through developments on sertic systems. (This assumes that roadways through
bcth kinds of development would be peved).
Costs of T-ubH c Services
On raje 102 in Section 5.2.1, Lanri Use, the follovin°; statement sppeffrs:
"The lsnd use pattern which should result in the Horsepen Creek basin
will be costly to accomodate from s public services perspective. It
cests mere to provide essential public services (transportation, util-
ities, schools, etc.) for a low density pattern than it does for a
high density pettern (RB-118)
This conclusion, possibly, wps drawn from studies of "established" develop-
ments of the same number of inhabitants, the difference beinf the spscin£
cf the living quarters . If, however,
th?re vers more ~«nple living within the same areal dimensions (a hifch density
development), it is not reasonable to expect that they vould require less
nufclic service than fever people in that same sized ersa (low density develop-
ment). It is repsonable to expect that there would be more school-age children
in the densely populated area, greater loads of trash and garbage generated,
more civil disturbances, traffic accidents and emergencies all reouiring corresp-
onding tax-paid services of larger proportions than where population density was
less. Hue to the controls imposed by the Guilford Health Department (approximately
1 sere lot size ner residence and sertic tsnk system standards) development usin£
the domestic system (the low density development) vill rrcbably proceed more slowly
than where city sewer lines were accessible (promoting hi^hor densities). This
stretch-out time vould also have some decided affects on the comparitive costs
of servicing.
-------
Review of ^13: Horseren Creek Basin Interceptor Frcject - James Rees
Militating Measures - Const ruction of the Greensbofo Thoro'fare Flan Facilities
Kultilnne roadways, bridges, and interchanges nroncsed in the Greensboro
Thorofpre Plan (short npme) transect ?nd disturb much of the Horseren Creek
Drainage Bpsin (the Greensboro City Reservoir System ftstershed). Although
citizens fully exrect that the highway planners will observe the K.^.F. Act
and develop a complete EIS for the entire rroject and submit it to the TJnviron-
rnentsl Frotection Agency, this construction is an inextricable port cf the deve.1
opment within the Basin. Commendably, Chapter 6. Miti»'Pting Measures cited ?
long list of legal instruments new existing or being considered by officials
that could be used to protect the watershed and city water quality. EIS
authors failed to mention, however, the planned roadway of the Creensboro Thoro-
wfttsr frcrn the pollution of pavement wash, the air from combustion products,
the general serenity from noise pollution, the wildlife habitat from detraction
all adverse conditions resulting fr
-------
RESEARCH ASSOCIATES
9119 ftUMMlT* AVKMUi
ORKINIIORO, N. C 2740i
Dec. 5, 1978
Mr. John E„ Hagan III
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, NE
Atlanta, GA 30308
Dear Mr. Hagan:
As a member of Audubon Society, we are interested in
conserving all national resources, including money. Therefore,
I favor Alternative 2E, as the most cost effective alternative,
Including a force main of 8" and gravity flow line of 12" for
gravity flow to NBC.
Radian Corp. is to be commended for its excellent evaluation
in this study. The Alternative 2E appears liberal enough to
meet future needs without being too conservative. The following
estimates may be noted to achieve same results.
1. Population Increase.
Present population is estimated at 8000 persons.
Estimated annual population growth rate for Greensboro
is about .7# and assuming 2.1% Increase, or 3 times
as much growth rate, this would mean a population
of about 13»000 persons in 20 years, indicating
'Radian estimate of 18,000 is very lihpral.
2. ^ Sewage Flows.
Future flows by Radian at 1.3 MGD is based on 70 gpdc,
but using a more liberal estimate of 90 gpdc for
estimated population and industrial growth rate
above this would mean about 1.2 MOD flov/, or about
same as Radian projection. Depending on slope,
outfall line may be raised to 15".
The very commendable presentation of re sear qt1 data by
Radian demonstrates its expertise in environmental engineering
and scientific studies and its findings Bhould be given highest
priority.
R. H. Souther
WATER POLLUTION CONTROL CONSULTANTS - INDUSTRIAL ft MUNICIPAL • RESEARCH • DESIGN • bJ|LD
-------
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
REGION IV
101 MARIETTA TOWER Slllte 1053
ATLANTA, GEORGIA 30323
OFFICE OF TH1;
Principal Regional Official
November 27, 1978
HEW-887-10-78
Mr. John E. Hagan, III
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30308
Subject: Greensboro - Guilford County, North Carolina
Horsepen Creek Interceptor
EPA Project No. C37036901
Dear Mr. Hagan:
We have reviewed the subject draft Environmental Impact Statement.
Based upon the data contained 1n the draft, 1t is our opinion that
the proposed action will have only a minor Impact upon the human
environment within the scope of this Department's review. The
impact statement has been adequately addressed for our comments.
Sincerely yours
James E. Yarbrough
Regional Environmental Officer
cc: A. McGee
R. Goldberg
-------
116 West Jones Street Raleigh 27603
James B. Hunt, Jr., Governor
Joseph W. Grimsley, Secretary
Division of State Budget and Management
John A. Williams, Jr., State Budget Officer
(919) 733-7061
January 31, 1979
Mr. John E. Hagan III
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, NE
Atlanta, GA. 30308
Re: SCH File #135-78; Draft EIS - Greensboro-Guilford County,
North Carolina; Horsepen Creek Interceptor
Dear Mr. Hagan:
The State Clearinghouse has received and reviewed the above
referenced project. As a result of this review, the State
Clearinghouse has received from Division of Policy Develop-
ment the attached memorandum.
Thank you for the opportunity to review the referenced draft
environmental impact statement.
If you have.questions regarding these comments please contact
Ms. Jane Sharp at 733-4131.
Sincerely,
Chrys Baggett (Mrs.)
Clearinghouse Director
CB:mw
cc: Region "G"
Attachment
-------
North Carolina _
Department of Administration
116 West Jonet Street Raleigh 27603
James B. Hunt, Jr., Governor Arnold Zogry
Joseph W. Grimsley, Secretary /^sbtan^Secretary for Policy and Management
MEMORANDUM
TO:
FROM:
Clearinghouse
Anne Taylor / au,y6&<
DATE: December 7, 1978
RE; EPA Project No. C 37Q 369 01
Horsepen Creek
I agree with the Secretary of Natural Resources and Community
Development that a comprehensive plan for growth management
(the 208 plan) in the Horsepen Creek Basin west of Greensboro
is vital to the success of the Horsepen Creek Interceptor, EPA
Project No. C 370 369 01*
We believe that the mitigating measures outlined in pages
105-110 need to be in place before the line is constructed,
since population and development pressures will quickly provide
the major adverse impacts on water quality associated with
urbanization in the Horsepen Creek area noted in the EIS
(pages 89-103).
It is suggested that implementation of the recommended miti-
gating measures begin with acquisition of lands for recreation
and conservation and a regular water monitoring program for
Horsepen Creek and Lake Brandt, and that they include all of
thoselisted on pages XVIII and XIX, as well as the above pages
(105-110).
AT/mf
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DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT. CORPS OF ENGINEERS
P. O. BOX 18S0
WILMINGTON. NORTH CAROLINA 28402
KR TO
SAWEN-E
1 December 1978
Hr. John E. Hagan III
Chief, EIS Branch
Environmental Protection Agency, Region 4
345 Courtland Street, N.E.
Atlanta, GA 30308
Dear Mr. Hagan:
o
I have reviewed the draft Environmental Impact Statement fd# the Horsepen
Creek Interceptor, Greensboro-Guilford County, North Carolina, EPA
Project No. C37036901 and have np comments to make on the contents of
that document.
The Wilmington District, Corps of Engineers, is also preparing to
initiate studies of the Greensboro area. In July 1977, Congress, in
response to a request from local government officials acting through
their Congressman, authorized the Chief of Engineers to conduct a water
resources investigation of Guilford County, N.C., under the Corps of
Engineers urban study program. This study will address the full range
of water resource problems and needs, including flood damage prevention,
water supply, water based recreation, and wastewater management. The
wastewater management portion of the study will be conducted in full
accordance with the Environmental Protection Agency's 208 Planning
Guidelines and will be coordinated fully with your agency. This study
is currently scheduled to be initiated in Fiscal Year 1980 depending
upon Congressional appropriation of study funds and should be completed
after a three-year study period.
If you have any questions regarding the more exact nature of our studies,
or if I can be of assistance to you in your studies, please feel free to
contact me. I appreciate this opportunity to review the Environmental
Statement, and I am looking forward to working closely with you on the
Corps' urban study.
Sincerely yours, /• y-
ADOLPmk. hight /
Colonel, Corps of Engineers
District Engineer
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United States Department of the Interior
OFFICE OF THE SECRETARY
Southeast Region 148 International Blvd., N.E. Atlanta, GA 30303
ER-78/1052
Mr. John E. Hagan III
Chief, EIS Branch
EPA, Region IV
345 Court!and Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
We have reviewed the draft environmental statement for the Horseoen
Sr^WhlU'sTwa NOrth Caro11'"- as re"uest«l
General Comments
The Department of the Interior's previous comments on Environmental
tStu^fA?n?M»nror?,nL;.tftement' hav# concern with
the lacK of infoffliatlon on cultural resources. We note » Haf-i
dency 1n this statement in that the Identl ??iat?onofcul turl re-
sources has been relegated to later stages of the proposed orolect
This procedure falls to provide adequate consideration of cultural*
resources In the early planning stages, a requirement of EPA's own
guidance 1n 40 CFlTRrt 6. Tta assertion OT pageM that the«T no
Indication of the existence of historical or archeologlcal resources
in the affected area 1s unsupported. The sutenin? stoS n^lndUatlon
that the considerations required by the National Historic Preservation
Act and Executive Order 11593 entered Into the^earl/plwnlnTfoTthe
project. We feel that, as a minimum, the environmental statement
should include specific comments and recommendations made by the State
Historic Preservation Officer and/or the State Archeologlst as to the
probability of encountering cultural resources or the need for a pro-
fessional survey. r
Specific Comments
Page 6, Paragraph 2
Facilities for the proposed action are designed to transfer as much as
2.4 million gallons per day of combined domestic and Industrial waste-
water to the North and South Buffalo Creek basins for treatment The
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relation of the Increased flows to the treatment capacity of the Buffaln
Creek plant and the effects of Increased flow of treated
receiving streams should be discussed. effluent on
Me appreciate the opportunity to comment.
Sincerely yours,
James H. Lee
Regional Environmental Officer
; £
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APPENDIX B
TRANSCRIPT OF THE DRAFT EIS PUBLIC HEARING
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BEFORE THE ENVIRONMENTAL PROTECTION AGENCY
V
GREENSBORO-GUILFORD COUNTY,
NORTH CAROLINA :
HORSEPEN CREEK INTERCEPTOR
EPA NO. C37036901
Coliseum Auditorium
Greensboro, North Carolina
Monday, November 20, 1978
The above-entitled matter came on for public
hearing pursuant to notice at 7:00 p.m.
BEFORE:
SANFORD W. HARVEY, JR.
Co-Chairman
Regional Counsel, Region IV
Environmental Protection Agency
Atlanta, Georgia
A. F. McRORIE
Director
Division of Environmental Management
North Carolina Department of Natural Resources
Members of Panel:
JIM FINGER, Director; Surveillance and Analysis
Division; Environmental Protection Agency
JOHN HAGAN, Chief; EIS Branch; Environmental
Protection Agency; Atlanta, Georgia
HAROLD DUHART, chief; North Carolina Section of
the Water Division; Environmental Protection
Agency
~ PRECISION REPORTING
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NMtih.'NonfrliuaiiM J7«n
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TABLE OF CONTENTS
Introduction
Pages 3-6
6-11
11-20
Chairman Harvey
Speakers:
Mr. Bob Cooper, EIS, Preparation Section
Mr. Kirk Holland, Radian Corporation
Mr. Forest Campbell, Chairman County
Commissioners 20-25
Mr. Jim Melvin, Mayor of Greensboro 26-31
Mr. Charles Melvin, Chamber of Commerce 31-33
Mr. Tom Hubert, Chamber of Commerce 33-37
Mr. Rhodes Corbett, Chamber of Commerce 37-40
Mr. Fred Clapp, Greensboro Board of Realtors 40-46
Dr. Paul Lutz, Guilford County Advisory
Board for Environmental Quality 46-49
Mr. Austin Elliott, Environmental Action
Coalition 50-53
Mr. Mark Schott, Greensboro Jaycees 53-56
Msi Carolyn Alien, League-of Women Voters 56-61
Mr. Jack Jezorek, citizen 61-63
Mr. Tom Duckwall, Audubon Society 64-67
Ms. Patricia Lutz, Sierra Club 67-69
Ms. Mazie J. Lev6nson, citizen 69-74
Mr. Frank Yo£k, Homebuilders Association 74
Mr. Hal Lewis, citizen 75-76
Mr. Roger Sekadlo, Executive Director of
the Airport Authority 76-77
Mr. Ray Shaw, City of Greensboro 77-80
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Durham, Chaptl Hlti (910) S49-06M
RaMgti (919)
P. O. Box 28163
Rattgfc, North Carolina 27011
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PROCEEDINGS 7:10 p.m.
CHAIRMAN HARVEY: Good evening. May I
call the meeting to order, please?
Welcome to this public hearing on the Draft
Environmental Impact Statement for the Horsepen Creek
portion of the Greensboro-Guilford County Wastewater
Treatment System.
I would like to begin by introducing the
hearing panel. I am Sanford Harvey/ Regional Counsel/
Co-Chairman from EPA Region IV in Atlanta. The other
Co-Chairman for this panel and to my immediate left is
Mr. Mac McRorie, Director of the Division on Environmenta _
Management from the North Carolina Department of Natural
Resources.
To his left is Mr. Jim Finger, Director of
the Surveillance and Analysis Division of EPA. To my
immediate right is Mr. John Hagan, Chiet of the EIS Branch
of EPA, Atlanta, and to his right, Mr. Harold Duhart,
Chief of the North Carolina Section of the Water Division
also of EPA.
People I would like to introduce who are not
a part of this hearing panel but are here to either
participate or to observe these proceedings are as
follows: Mr. Jim Melvin, Mayor of the City of
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IP. 0. Box »1M
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Greensboro; Mr. Forest Campbell, Chairman, Board of
County Commissioners, Guilford County. I would also
like to recognize Commissioner Deal present and
representing the City Council for the City of Greensboro;
Councilpersons Bowie, McMdnus, Forbes and Jimmy Barber.
I also would like to recognize the Mayor
Pro-Tem, Mr. Neusbaum of the City of Greensboro.
Our particular thanks this evening are also
extended to Mr. Ray Shaw, Assistant Director of Public
Works for the City of Greensboro, and to Mr. Larry
Harvell, Director of Environmental Services of Guilford
County, for providing these arrangements this evening.
Are there any other elected officials that I
have overlooked? If so, if you would like to stand and
state your name, I will recognize you at this time.
(No response.)
CHAIRMAN HARVEY: Very well.
jae National Environmental Policy Act of
1969, requires an agency of the Federal Government to
prepare an environmental impact statement whenever that
agency proposes to take a Federal action significantly
affecting the quality of the human environment. In
addition, the North Carolina Environmental Policy Act
of 1971, requires an agency of the State Government to
prepare an environmental impact statement whenever that
D PRECISION REPORTING
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(010) 0*3-0066
P. 0. Box 80119
RtMflh. North Caroline 27811
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agency proposes to take.a state action significantly
affecting the quality of the human environment.
Guilford County, North Carolina applied for a
grant from the United States Environmental Protection
Agency and the North Carolina Department of Natural
Resources and Community Development to develop a waste-
water treatment system to service the Horsepen Creek
area.
The Environmental Protection Agency and the
state, responding to the mandate of their respective
Environmental Policy Acts, determined that .the issuance
of funds for the proposed wastewater treatment facilities
was a major Federal and state action significantly
affecting the quality of the environment.
Accordingly, on April 5th, 1976, the
Environmental Protection Agency and North Carolina
Department of Natural Resources and Community Development
issued a Notice of Intent to prepare a joint Environmental
Impact Statement.
On November 10th, 1976, the Governmental
agencies jointly held a public meeting to discuss the
objectives of the Environmental Impact Statement and the
public involvement program.
Pursuant to the guidelines of the Council on
Environmental Quality and the rules and regulations of
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the Environmental Protection Agency and the North
Carolina Department of Natural Resources and Community
Development, with regard to the preparation t £' Environ-
mental Impact Statements, this public hearing is being
held to receive comments from the public on the Draft
Environmental Impact Statement.
This Draft is being discussed in a public
forum to encourage full participation of the public in
the decision making process and to develop improved
public understanding of projects funded with Federal and
state funds.
A report of these proceedings will be made
and become a part of the record. Notice of the public
hearing was published in the Greensboro Daily News on
October 22nd and November 19th, 1978.
The Draft Environmental Impact Statement was
submitted to the Environmental Protection Office of
Federal Activities and made available to the public on
October 13th, 1978.
Before we begin citizen testimony, Mr. Bob
Cooper of the Environmental Impact Statement Preparation
Section will give us a brief summary of the.project.
MR. COOPER: Thank you, Sanford.
This Draft Environmental Impact Statement
addresses the provision of wastewater transmission
C~71 PRECIStON REPORTING
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treatment and disposal facilities for the Horsepen
Creek area. The objectives of this project are the
protection and enhancement of surface and groundwater
resources for human consumption, for fish and wildlife,
and for recreational and esthetic uses. A plan to meet
these objectives was prepared by Guilford County.
interceptor sewer line running the length of the Horsepen
Creek basin with a maximum size of 42 inches. This
proposal stimulated considerable controversy among
citizens in this area.
degradation of water quality and other growth related
impacts. Based upon these concerns, the Environmental
Protection Agency and the North Carolina Department of
Natural Resources and Community Development have
prepared an Environmental Impact Statement.
segment of the Greensboro-Guilford County 201 Facility
Plan. The other portions of that plan dealing mainly
with the site location for the South Buffalo Creek
wastewater treatment facility have been covered in a
previous EIS.
The objectives of this EIS are to establish
the existing conditions in the Greensboro area, to
The plan recommended the construction of an
The concerns expressed included the potential
This EIS covers only the Horsepen Creek
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evaluate alternatives for wastewater transmission
treatment and disposal, to assess the environmental
effects of the proposed action, and to recommend
mitigative measures to avoid adverse impacts.
investigated in detail. Alternatives 1 through 4
provide sewer service throughout the Horsepen Creek
basin and can be sized for existing or projected year
2000 flow. Alternative 5 is the no action alternative
which maintains the existing Horsepen Creek collection
system.
industrial flow into the South Buffalo Creek collection
system and the maintenance of the existing Horsepen Creek
collection system. In both alternatives 5 and 6,
wastewater generated from new residential development
will be served by septic tanks.
cost and environmental evaluation. The major input into
the environmental evaluation was a water quality
monitoring and modeling program which was conducted as
part of the EIS. Kirk Holland of Radian Corporation
will discuss this analysis following my presentation.
The results of this alternatives evaluation
show that water quality and land use impacts are the
In the draft, six system alternatives were
Alternative 6 involves a system to discharge
These alternatives were then subject to a
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most significant to this project. Selection of the ^
no action or modified no action alternatives would
encourage low density development throughout the basin.
The existing service alternatives would also generally
tend to encourage low density development with a
limited amount of higher density development connected
to the new sewer line.
for much higher development densities throughout the
basin. In the short term, this development will probably
be concentrated adjacent to those areas currently
developed. Ultimately, development would probably occur
throughout the basin.
existing service alternatives will minimize the concen-
tration of pollutants generated in urban runoff. These
alternatives will have a significantly smaller potential
adverse impact to water quality in Lake Brandt than the
future service alternatives with their substantially
higher land use densities.
quality could result from problems with the existing
system of lift stations and septic tank failures. The
no action and modified no actipn alternatives would not
alleviate these potential hazards.
The future service alternatives will provide
The less intensive land use densities of the
Other potential adverse impacts to water
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Alternative IE and 2E would do the best job^
in this regard by eliminating all but one lift station.
Alternative 2E is considered the most environmentally
acceptable alternative since it alleviates the existing
problems with the smallest encouragement of high density
EXS has been the input of the EIS Advisory Committee.
This group consists of representatives of local
governmental^bodies and citizen interest groups. This
Committee has reviewed and commented on all EIS outputs
and has suggested alternatives to be evaluated.
and the state received new existing flow information
and other related information generated by the County and
the City. A detailed review of this information will not
be done at this time because an EIS document is not the
appropriate place for detailed design information.
Step II Phase of detailed project design following
completion of the final EIS. The pipe sizes presented
in the draft EIS were estimates based upon the information
available. The specific diameter of the pipe that is
finally selected will not affect the choice of
alternative in the EIS.
development.
An important part of the preparation of the
Following publication of the draft EIS, EPA
This design analysis will be done during the
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The purpose of the EIS is to choose an
alternative for service aiming those viable alternatives
identified in the EIS process. The diameter of the pipe
that is selected will be that which is necessary to
accommodate the alternative that is chosen in the final
EIS.
We would now like to introduce Mr. Kirk
Holland from Radian Corporation who will discuss the
monitoring and modeling program.
MR. HOLLAND: Thank you.
My name is Kirk Holland. I am the Program
Manager for Radian Corporation in Austin# Texas. Radian
was commissioned to perform a comprehensive environmental
impact statement for the Horsepen Creek Interceptor
pursuant to the National Environmental Policy Act.
The assessment was to use readily available
existing information and professional judgment in the
interpretation of those data.
In the course of our analysis, it became
clear that more data and more interpretative analysis
was required to gauge the water quality effects of the
interceptor, particularly the secondary water quality
effects of the Horsepen Creek Interceptor on Lake Brandt.
The reason for this belief was that the
interceptor has potential for encouraging intensive land
CU PRECISION REPORTING
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use in the basin. Furthermore, the water quality
effects from the intensity of this land use are
uncertain. National weather data indicates that
generally urbanizing areas have potential for creating
pollutants that nay degrade water quality, particularly
those that are used as water suppliers of the water
supplies.
There is also a strong indication that such
effects are quite site specific and require site
specific sifudies to ascertain the effects.
The general methodology that we used was to
monitor and then model the water quality of the Horsepen
Creek basin under several different development scenariosf
We monitored the current conditions in Horsepen Creek
in a basin that is believed to be similar to the way
Horsepen Creek basin could evolve in the design period,
mainly the uppermost portions of North Buffalo Creek
above the point source discharges.
This essentially represented what we feel is
a representative mix of residential, commercial,
industrial land uses in the area.
Then we projected the impacts that will accruej
from further development of the Horsepen Creek basin
using the monitoring data to calibrate a model that
would give us an indication of what water quality impacts!
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1 could accrue upon such development.
2 I emphasize the word "indicate." This is not
3 a perfect predictor. The state of the art in water
4 quality predictions does not allow such prediction an
5 the present time.
6 It should also be noted that other methods
7 which are somewhat less sophisticated than those that
8 were used in this study predict higher pollutant levels
9 than the ones that we predicted; that is, worse water
10 quality effects.
11 However, we believe that this methodology
12 that was used represents the best available tool
13 presently at hand to evaluate these water quality impacts
14 The monitoring data indicated that the water
(
15 quality of Horsepen Creek itself is good: low bod.'s,
16 high desolved oxygen, fairly low dissolved solids.
17 The monitoring data indicated that Lake Brandt has fair
18 to good overall quality. The water is soft; conductivity
19 regions below which indicate low levels of dissolved
20 solids. pH measurements are slightly acid to nutrient,
21 which are typical of forested areas.
22 However, there are wide seasonal variations
23 in the pH of Lake Brandt. It should be mentioned that
our monitoring program was carried out during a time
25 when the lake level was at a low elevation. This would
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PRECISION REPORTING
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enhance any adverse water quality processes that would
tend to degrade the water quality.
The low total alkalinity in Lake Brandt
provides low buffering capacity to resist any pH changes
This makes the lake susceptible to upstream discharges
and variations in water quality, which might tend to
alter the pH. These changes in pH in the lake could
indicate that geochemical processes that result in
concentration of adverse water quality parameters could
occur. I aifi not saying they do occur, but there is a
potential for them to occur.
The heavy metals concentrations in particular
are generally low on the lake with two possible
exceptions: one is lead, and the other is arsenic.
Our monitoring data indicates that the lead concentra-
tions in the Horsepen Creek arm of Lake Brandt and at
the dam on Lake Brandt exceeded the maximum concentration
of lead for protection of fishlife.
One of these values also exceeded the
concentration for protection of public drinking water
supplies.
It should be noted that other evaluations have
not shown lead concentrations this great. But remember,
we were sampling during a more or less worse case
condition with respect to lake water quality.
] PRECISION REPORTING
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Arsenic concentrations, while low in
Horsepen Creek itself, appear to be concentrated in the
lake water quality. We inferred that this could be
recycling of arsenic-contained sediments in the bottom
of the lake. The sources of arsenic in the lake are
unknown.
as moderately eutrophic- It does firmly stratify, and
dissolved oxygen is depleted in at least the bottom
portions. There is also noticeable chemical stratifi-
cation during the summer months. This indicates a
concomitant biological activity within the Lake Brandt
ecosystem.
while hot present in extreme concentrations, are
present in quantities more than adequate for excessive
growth of aquatic vegetation. Lake Brandt is particularly
susceptible to nutrient inputs because of its shallowness.
we calibrated an urban area runoff model called the
"storm model storage treatment overland flow model"
developed by the Corps of Engineers for modeling
processes in urban areas with specific reference to
eight different parameters. Of these parameters,
The trophic state.of the lake is described
considerable degree of organic decay processes and
Aquatic macronutrients, hydrogen, phosphorus
With this monitoring data set into context
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suspended solids, tjotal nitrogen, orthophosphorus
were of primary importance.
The storm model does not treat heavy metals
in anything other than a conservative parameter; that
is, no removal processes are taken into account. In
this respect, the model is conservative if it is used
for heavy metals.
The model was calibrated to the upper North
Buffalo basin and was exercised for different develop-
ment scenariosvarious levels of development and various)
kinds of development; that is, with full sewage service
and with septic tank service to try to gain appreciation
for the sensitivity of land use effects on water
quality.
We found that the detrimental effects on
water quality was proportional to the extensiveness and
intensiveness of development. Beyond that, we
detected in the modeling results that there was
some difference between the full sewage service
and full septxc tank service impacts. I should
also mention, and I should have mentioned earlier, -that
the storm model was only applied to that area which was
urbanized. Other parts of Horsepen Creek basin.were
non-urban in character, and these were modeled using
correlations based on the universal soil equation of the
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Soil Conservation Service
In aggregate, the urban plus non-urban
pollutant loadings through the design year, using these
statements, the development scenarios could be ranked
in the following order: from best to worse in terms of
water quality. This is based solely on pollutant
loadings from Horsepen Creek to Lake Brandt. Best would
be serviced only by sanitary sewers. Second best would
be sanitary sewer service for the existing development
only, followed by expansion of facilities to serve the
existing development; no action, and worse could be
future service based only on septic tank service.
Now, that ranking which ranked service only
by sanitary sewers first and future service only by
septic tanks last, more or less valued the range in
water quality impacts that we felt could accrue under
a full development scenario.
However, in terms of the overall environmental
benefit ultimately from a water quality prospective, we
believe that sanitary sewer service of existing
development only, if accompanied by appropriate
institutional safeguards--not necessarily prohibitions
on anything for further development—appears most
attractive.
On the other hand, the no action alternative
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appeared most detrimenal. The other alternatives of
development scenarios, if you will, each have at least
one compelling disadvantage relative to the best one,
including conceivable higher lead loadings during
commercial and industrial development. This has to do
with the traffic that would be generated by development
in the basin, and particularly, industries in the basin.
land, particularly with a full septic tank development
and encouragement of much higher density development
beyond the planning period—in the period beyond the
year 2000—this £ffect would accrue with development with
full septic tank service. Development only—I am
sorry—accrued only with development by full sewage.
or less consume all available land in the Horsepen Greek
basin by the design year, and in fact, could encroach
upon some environmentally sensitive lands.
solids, lead and phosphorus appear to us to be of most
concern;on these lead loadings are most insensitive" to
the sewer versus unsewered development. They are
sensitive to the intensity of development, the density of
development, if you will.
Development of environmentally sensitive
Development only by septic tanks would more
Of the pollutants considered, suspended
Suspended solids are probably most sensitive
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due to the magnified impact upon the light transmission
properties of the lake life and possible eutrophication
problems that they may engender.
These suspended solids effects would be
increased for any alternative which encouraged greater
septic tank development.
The results of our study affected to some
extent the choice of the alternatives. I should say
the monitoring affected to some extent the choice of—
environmental monitoring affected the choice of
alternatives. However, the monitoring and modeling
results have to be viewed in context of the total water
quality picture. So, therefore, they provide only
partial input into the choice of alternatives.
If we had to summarize our basic findings
with respect to the results, it would appear that sewering
in the future population would provide for generally
higher density growth development ultimately, which is
undesirable from the water quality prospective, parti-
cularly in the water quality affected is a public water
supply.
We felt like the existing system of lift
stations, force mains, which is fairly complex, should
be reduced to decrease the probability of surcharging
overflows and more or less periodic catastrophic water
n PRECISION REPORTING
AND TRANSCRIBING, INC.
DlHtnm. Cft** Hill («1«l MM6M
RMIgh (»1t) MMOM
~ p. o. box Mm
MMflll. Nwttl CamiM 37011
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quality degradation.
Our control future growth solely using septic
tanks is also undesirable due to general poor soil
suitabilities, development of environmentally sensitive
lands, and increased probability of malfunctions of. the
septic tanks.
Ladies and gentlemen, I would like to express
the wishes of the panel to limit your testimony this
evening to a period of ten minutes. I think that that
will enable everyone who is going to speak to give their
full consideration to the panel.
I would also ask that if any of you have
prepared texts, if you have a copy of the same, if you
could provide the panel with a copy to enable us to
more closely follow your remarks, it would be gratefully
appreciated.
Unless there are any questions on those two
rules, at this point I would like to begin our public
participation by calling upon Mr. Forest Campbell,
Chairman, County Commissioners.
COMMISSIONER CAMPBELL: Mr. Harvey and
members of the panel, we have reviewed the Draft
Environmental Impact Statement and we are very concerned
Thank you.
CHAIRMAN HARVEY:
Thank you very much.
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about the wisdom of the decision to select less than \
an adequate sewer system.
It has been our position since 1966, that
this interceptor sewer system be designed to accommodate
the existing and full future development of the basin.
This remains our position today.
The EIS acknowledges the poor suitability of
soils in the basin to accommodate properly functioning
septic tanks. We agree with this fact.
The EIS states that full development of the
basin will occur eventually no matter the existence,
configuration or capacity of any public sewer system.
We agree with this conclusion.
The EIS assigns detrimental impacts to Lake
Brandt fron malfunctioning septic tanks. The EIS points
out the spiawl and inordinate consumption of open space
in the basi.a accompanied with development of septic
tanks. We l.gree with this conclusion as well.
vre Strongly disagree with the Document's
inference tijat local government has an inadequate
deaire and/qc regulatory tools to greatly mitigate many
of the secc/idary impacts created by the full basin
development on public sewer.
Available to us locally is the City-County
Water and fSewer Extension Agreement which provides
"~n PRECISION REPORTING
ry T AND TRANSCRIBING, INC.
Ourfcam, Cteptl m (fit)
RfMgfc <•!•) ~
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RHN§h. ttortfi Caroflfta 17#n
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policy and direction for managing these services.
Since 1964, we have utilized our zoning authority to
regulate types of development. In fact, our Planned
Unit Development Zone, which is specifically designed
to protect watershed areas and to create open space,
will not work under a septic tank development scenario.
Erosion and Sedmiment Control Ordinance. A Stormwater
Management Ordinance is presently under consideration.
The County and the City of Greensboro Planning
Departments, in conjunction with the Regional Council
of Governments, have been, and remain, involved in long
range planning for the area. Thoroughfare planning in
the area has been accomplished in conjunction with the
City and the Department of Transportation in the State
of North Carolina.
concern for water quality. Many of our developmental
zones are specifically geared to regulate watershed
development. We have long discouraged the location of
"wet" industries in our community.
that we feel that if the basin is to eventually develop
fully, then the development should be placed on public
sewer rather than septic tanks.
V7e have our Subdivision Ordinance and our
Our record clearly indicates a vital local
It is, in fact, this concern for Lake Brandt
in PRECISION REPORTING
l] r AND TRANSCRIBING, INC.
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IS
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We are convinced that the decision to
knowingly install a less than adequate sewer will have
grave consequences, both environmentally and financially,]
for us in the future.
EPA does have the option to endorse a much
more sound concept. We, the local leaders of government,
ask that you support and assist us by exercising that
option. We think that you should select a system which
will much better meet our future needs and afford longer-|
term protection than the alternative chosen in the
Draft Environmental Impact Statement.
And in addition to that, I have an attachment,
a letter dated today, addressed to the Regional IV
Administrator for EPA, which contains more specific
concerns that we have with the Draft EIS. I would like
to ckll those to the attention of the panel at this
time:
. .We feel the use of 70 gallons per
day per capita is too low in computing
flow pro ject ions.
". . .The assumption that all industrial
waste by-passes the Stage Coach Trail
Life Station is erroneous."
. .Wastewater generation from the
Brush Creek Basin," which is the Cardinal
raw
JQjJ.t
PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, Ohaptt HID (919) 549-0698
totolgti <019) 832-9086
~ P. 0. Box asies
flaMgh, North Carolina 2761)
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Corporation System, "to the north should be
handled by the Horsepen Life Station
rather than retaining the Brush Creek
Station in such close proximity to the
proposed system."
. .The system should be designed to
accommodate flows from the Airport
Terminal Complex," projected to be
". .".60,425 gallons per day by 1935,
and 153,000 gallons per day by 1995."
". . .According to flow figures provided
recently by the City of Greensboro from
on-site monitoring efforts, the 2E
System as described in the Draft could
not accommodate today's flow, much less
'limited1 growth in the future."
". . .The Draft should incorporate, in
much more concise terms, the mitigating
measures for secondary impacts available
to and utilized by local government,"
which I have summarized previously."
". . .The treatment capabilities of the
Lake Townsend Filter Plant should be
more fully addressed."
". . .The Federal mandate to ultimately
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eliminate the use of leaded gasoline
should be addressed in the discussion
of projected lead loading levels in
Lake Brandt."
". . .We are disappointed with EPA's
selection of a 'limited' growth alternative.
We in Guilford County can and have
certainly attempted to direct and regulate
growth, but as the Draft points out, the
basin will continue to develop long after
Alternative 2E has reached capacity."
We ask then:
". . .Will we then be in the same
predicament in which we find ourselves
today?"
". . .We respectfully request that the
longer-term impact of basin development
be fully considered before a final
decision is made by your office."
In addition to that, I have a further
attachment which I will hand out without reading which
contains many more of our concerns with regard to more
recent findings under our studies.
Thank you, sir.
CHAIRMAN HARVEY
Thank you
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Before you leave the microphone, may I ask
if the Co-Chairman and any of the panel members have any
questions that you wish to address at this time to Mr.
Campbell?
(No response.)
CHAIRMAN HARVEY: Very well, then.
Thank you very much, sir.
COMMISSIONER CAMPBELL: Thank you, Mr*.
Harvey.
CHAIRMAN HARVEY: The panel desires to
recognize Mr. Jim Melvin, Mayor of Greensboro.
MAYOR MELVIN: Mr. Harvey, ladies
and gentlemen, members of the panel, I would prefer
personally to ad lib and to speak from the cuff, but
because of the importance of this subject and the need
to be sure that everything that I intended to say is
properly before you in the record, I will read my
prepared statement which I will furnish to the Committee
right after my presentation.
Hopefully, this is the last hearing that will
be necessary in order to make pollution a vagrant in
Guilford County a reality. We have finally decided on
a site for the metro plant. We have decided that an
outfall in Horsepen Creek is desirable and has less
adverse environmental impact than for the area to
C~1 PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, Chapel Hill (919) 549-0688
Rafai0h (919) 632-9065
IP. 0. Box 26163
Ralatgh, North Carolina 27611
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V
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develop on septic tanks.
What we will be discussing tonight, and I
want to emphasize this, should be the function of Step
II Design Phase of this project and not of the Step I
Planning Phase.
We have carefully studied the Draft
Environmental Impact Statement. We are in agreement with
many of the conclusions which have been known for years.
The City of Greensboro has worked closely with Guilford
County since 1965, to provide an orderly development of
a larger supply of sanitary sewer systems for those in
our community who happen to live and work outside the
corporate limits of the City of Greensboro.
I might add that this joint cooperative
agreement was signed even before the formation of the
EPA. The agreement in existence has been a model for
others throughout this country, and it has been
successful. The intergovernmental relationship between
Guilford County and Greensboro has been contributory in
making the quality of life in this community so good
that a recent study by the University of Nebraska has
ranked us fifth best community in this nation in which
to live.
I might add that we were in some mighty good
company.
C~P PRECISION REPORTING
AND TRANSCRIBING, INC.
~ p. o.»« mm
Worth QaraUfui snu
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2!
As previously pointed out by my colleague,
Forest Campbell, Chairman of the Guilford County
Commissioners, regulation of the development has been
controlled by zoning. Subdivision ordinances and
erosion and sedimentation control ordinances are in
effect. And I might restate that: they are in effect.
Stormwater management will be a reality
shortly. The County and City now are planning for a
long-range water supply project in conjunction with the
state and Federal Government.
I cite these to show what local government
is doing to enhance the environment in which we live and
to refute this statement in the Draft EIG that:
". . .a lack of desire to mitigate
secondary impact exists within local
government."
And quite frankly, we take that charge very
seriously and it hurts us deeply. We have the tools
and the will for good environmental quality control.
I might add here that the Draft EIS does recognize that
mitigating methods to protect the quality of water in
Lake Brandt are already in use or proposed. More
importantly, we have the support of the people.
A survey completed this month indicates that
over seventy percent of the people in our community feel
CJ PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, Chapal Hill (010) S49460B
Ralalgh (919) *32-0065
~ • P. 0. Box 20163
Rftlftiff), North Carolina 27011
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IS
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that the quality of life in our community has improved
since they have lived here. The survey also indicates
that they are vitally interested in environmental matters
That sane study showed that nearly eighty-five
percent of those surveyed gave high marks to both local
governments regarding regulations, services and taxes.
So, we must be doing something right.
It is fashionable.to blast the EPA at every
opportunity. But I am going to forego that opportunity
tonight. It is our sincere feeling, however, that the
EPA has gotten some very, very bad advice from its
consultant.. And as late as this afternoon, the Radian
Corporation, who is the consultant, admitted that they
overlooked and left out vital and significant information
which are pertinent to this decision that we are here
for tonight—as late as this afternoon.
But then everyone errs occasionally. And all
that we ask is that EPA not take a concrete position on
specific pipe size, but rather let the engineers design
the system based upon existing conditions, being consis-
tent with the agreed upon population to be served in the
year 2000.
If this is done, we are confident that the
interest of all can be served to the fullest. I would
close by emphasizing three major points: one, the
PRECISION REPORTING
AND TRANSCRIBING, INC.
Owtam, Otupal Hill (BIO MMMa
JQ *• .0; (Wig!*
MMgh trail
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engineering relating to the pipe size quite frankly
is lousy, jyhen pipe twenty feet deep supposedly cost
the same to install as an equivalent size pipe six feet
deep and then do not even then conform to the required
state standards, then lousy is the kind—is the only
word that I can use.
I suspect that the main problem is that they
did not know which way the sewage flowed by their own
admission this afternoon.
Two, controls dealing with growth in the
basin to protect the quality of water in Lake Brandt
are in place and are acknowledged in the Draft EIS,
which refute many of the things that Mr. Harvey pointed
out earlier.
Three, the question of 208 Planning, and I
want to emphasize this. The question of 208 Planning is
of no concern in this question. We have been told
repeatedly that 208 would never be a question. And yet,
again, as late as this afternoon, we were told that it
was a concern.
Where an area is not designated as a
208 area and the responsibility becomes one of the state,
in this case, North Carolina, the plan which the county
has set forth for handling the wastewater in Horsepen
Creek is not an unreasonablr.one.lt is acceptable to the
,3n
PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, Ch**J Hill (019) 94*0691
RaJtlflh (911) 0984066
3 P. 0. Box 29198
RaMgti, North Ctroftaa 27011
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State of North Carolina and to the City of Greensboro,
and we wholeheartedly support it.
Thank you very much.
CHAIRMAN HARVEY: Thank you, Mr. Mayor.
Any questions from any of the panel members?
(No response.)
CHAIRMAN HARVEY: Apparently not.
The panel recognizes Charles Melvin of the
Greensboro Chamber of Commerce.
MR. MELVIN: Mr. Harvey and members
of the panel, my name is Charles Melvin. I am President
of the Greensboro Chamber of Commerce.
The Chamber is a voluntary organization of
over 1800 civic and business members who are vitally
concerned with the orderly growth and development of the
Greensboro area.
We understand that the purpose of tonight's
hearing is for EPA to receive comments on the Draft
Environmental Impact Statement for the Horsepen Creek
basin. We also understand that there are questions of
fact yet to be resolved between EPA and the Council.
These questions, as we understand them, relate primarily
to the existing and anticipated sewage flow and
engineering factors concerning the design of the
collection system.
IC~3 PRECISION REPORTING
AND TRANSCRIBING, INC.
~
Ourtiam, OMp* Mil (•<*) M*46M
RtUfch (tit) Nt-NW
P. 0. los MM
KaMfh. Neflh CwoIIm 97*11
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We urge EPA to meet with the Council and tc
resolve such questions in a mutually satisfactory-
manner .
in a cooperative relationship with Guilford County and
the City of Greensboro. We believe that these
coordinated efforts have been very beneficial to our
community. The Chamber urges that EPA in this matter
also work closely with Guilford County to achieve a
wastewater collecting system adequate and appropriate
for the level of development forecasted to occur.
wastewater facilities in the Horsepen Creek basin for
several reasons: first, it is the community's major
growth center with significant residential development;
second, as the center for industrial growth, it is an
area which affords residents of our community opportunity
for increased jobs or increased employment levels in the
future; third, of course, has been pointed out here, and
it is a watershed for our community's water supply.
We are vitally interested in the
protection of that supply.
Fourth, because of the extensive urban
development which has already occurred in that basin, we
are anxious to see the completion of a public wastewater
The Chamber has worked for a number of years
The Chamber is very vitally concerned about
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V 33
collecting facility in order that septic tank-type \
development need no longer occur in that area.
For these reasons, the Chamber of Commerce
urges construction of an interceptor sewer adequate to
serve the ultimate development in the basin area. If
EPA does not concur in this position, we believe that
the public interest requirement that a system consistent
with optimum community development and a meaningful
cost benefit relationship and evaluation be constructed.
The Chamber urges elimination of any
additional delays. Accordingly, we support construction
of an interceptor sewer judged by the county based upon
sound engineering studies to be appropriate for existing
and future development of the Horsepen Creek basin.
Thank you very much.
CHAIRMAN HARVEY: Thank you, sir.
The panel would call upon Tom Hubert, also
of the Greensboro Chamber of Commerce.
MR. HUBERT: Mr. Harvey, panel,
ladies and gentlemen, my name is Tom Hubert. I am
Chairman of the Chamber's Council on Community Planning
and Development.
The Board of Directors of the Chamber of
Commerce has charged our Council with maintaining and
improving the quality of life for all of our citizens.
PRECISION REPORTING
AND TRANSCRIBING, INC.
Outturn, OtMpd Hill («t» Iwmn
MMBh (•mNMOM
if—| ft O. »o* 2*1(0
I WMHk North OwMna !7eti
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We, indeed, are proud of the quality and the integrity
of our local governments, both elected and at the staff
level.
We are appalled that the Radian Corporation
could submit and that EPA would accept such an
incompetent paper—an expensive research paper—p.aid for
by we, the taxpayers, that did not consider existing
conditions, utilize available topo maps or bother to
check the flow of existing lift stations.
We, are very concerned that the Federal
Government, in this case in the form of EPA, would
attempt to dictate to local governments how to control
their affairs.
The innuendo that our local government is
incompetent and unable to properly legislate local
ordinances is unconscionable, in my opinion.
These are not truths, and we ask that EPA
not make a decision on this important interceptor sewer
based on the incompetent document that has been presentee
to me this date at least.
The Chamber has consistently supported the
objective of providing an interceptor sewer sufficiently
large to accommodate local development of the Horsepen
basin. The reasons for this position of the Chamber
are several: first, the area will continue to develop
PRECISION REPORTING
AND TRANSCRIBING, INC.
Ourham, Cfiapol Mill (919) fl49 0flW
fetftyi (919) M24096
~ P. 0. Box 39199
RftMgh, North Carolina 278n
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as a consequence of the reasonable economic forces at \
play, the demand for housing and industries in the
basin itself; second, a sizeable investment in public
and private facilities has already been made. The
investment would be wasted if a reasonable development
does not permit it; third, the area is in the watershed
of Lake Brandt. The center septic tanks and lift
station can be eliminated within this basin. The
centers of the community will be assured of protecting
one of its valuable water supply reservoirs. Fourth/
economy demands that the maximum size interceptor sewer
consistent with development objectives and environmental
considerations should be constructed now.
its objective in the Draft EIS. It appears that EPA
is proposing to control the density of the development
within the basin. We believe this and related land
use decisions are solely the responsibility of
appropriate and competent local government.
alternate interceptor sewer which would accommodate
the existing development plus a limited amount of new
development. In rough numbers, this appears to
convert to an interceptor sewer capable of handling
the wastewater flow generated by the 3,000 existing
The Chamber finds a hindrance in achieving
The Draft EIS suggests that EPA prefers an
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residents plus approximately 4,000 additional residents^
by the year 2000.
However, this leaves over 6,000 individuals
who would have to be served by private sewer systems or
be denied the opportunity to live in the Horsepen Creek
basin.
We share EPA's concern for protection of
Lake Brandt. After all, we drink the water, and you
all don't. We share the concern of the adverse effects
of septic tanks upon Lake Brandt. Consquently, we urge
EPA to select an alternate which protects the water,
allows a reasonable level of development and eliminates
existing septic tanks, as well as prevents the need for
future septic tanks.
This would necessitate, as a minimum, an
interceptor sewer of sufficient size to accommodate the
flow anticipated from the forecast of population for the
year 2000 of over 18,000 people.
Greensboro has good development because of
its responsible private developers and the quality of
its public leadership. Our community's planning has*
been good. The regulation of land use has been good.
Growth will surely occur in the Horsepen Creek basin
irregardless of what we do here this evening.
The question before us all is how to insure
C7~3 PRECISION REPORTING
AND TRANSCRIBING, INC.
Durtwp, Chtptl MM (lt»H
awt
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the continued high quality of development of our
community, and at the same time protect the Lake Brandt
water supply.
We believe the best way to do this is to get
rid of septic tanks. We need an interceptor sewer
adequate to serve the anticipated level of development
proposed to be permitted under city and county land use
plans, policies and regulatory ordinances. I might a£d
to include the city, county and state, with Howard
Lee's addendum to the EIS papers.
Thank you very much, sir, for your time.
CHAIRMAN HARVEY: Thank you, sir.
The panel will call upon Mr. Rhodes Corbett.
MR. CORBETT: Mr. Harvey, gentlemen,
I am Rhodes Corbett, Vice Chairman of the Greensboro
Chamber of Commerce, Council on Economic Development.
I am here to state our concern about the potential
adverse economic impact of an interceptor sewer.
improperly sized for Horsepen Creek basin.
The basin is the community's primary growth
area. Its population exceeds 8,000 people today. By the
year 2000, the population is expected to be more than
18,000 people. It is also the community's primary
industrial growth area, and in the properties near the
airport, over 3,000 acres are zoned for industrial use.
PRECISION REPORTING
AND TRANSCRIBING, INC.
Outwit. Chap* HtH (tin MMM1
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In
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Over 600 acres are currently used for
industrial purposes. This area, incidentally, is served
by sewer lines considerably larger than the line proposed
in the tentative draft.
Additionally, there are over 2400 acres yet
available for development in this industrial zoned area.
This constitutes this community's largest single
concentration of such property and subsequent resource
base for new job opportunities.
According to the Draft EIS, there appears to be
constraints placed upon the commercial and industrial
development, with prior reports having suggested a
limitation of 210 acres of commercial development and
150 acres of industrial development being allowed by
the year 20 00.
This type of land use decision can best be
made by the appropriate local government in response to
a demand for such land and a consideration of our
community's best interest.
Any limitation of commercial or industrial
acreage on an arbitrary basis by any Federal agency is
inappropriate. Such a position by any Federal agency
is contrary to the President's National Urban Policy
objective of creating new jobs in our urban areas.
In addition, such arbitrary decisions are not consistent
C"P PRECISION REPORTING
AND TRANSCRIBING, INC.
Outturn, Chap*) HUI (t1«) MMMt
~ I (910) I
P. 0. Box .28163
I RaMgfc. North CwoUna (7*11
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— — 39
1 with the President's policy establishing a new urban \
2 partnership between the public sector and the private
3 sector, which will foster the creation of new jobs.
4 I would like to summarize the Chamber's
5 position. First, responsive, public agencies should
6 construct a sewer adequate to serve existing and future
7 development, since the area continues to be the most
8 desirable area for residential and related development,
9 Secondly, continued industrial development in the airport
10 area is essential to the economic strength of this
11 community and to the creation of new jobs for this
12 community.
13 Third, local governments are the appropriate
14 agencies for exercising developmental decisions as to
15 the extent and type of land use to be allowed within
16 the basin.
17 Fourth, there appear to be reasonable
18 alternatives to protect Lake Brandt for the period of
19 time which it will continue to be needed as a water
supply reservoir. Let me again emphasize what our
Chamber of Commerce President, Charles Melvin, has
22 already said: if EPA does not concur and change its
23 position, then we urge that an agreement be reached
24 between EPA and Guilford County to provide an interceptor
sewer and other wastewater collection system facilities
PRECISION REPORTING
AND TRANSCRIBING, INC.
p.aamWM
NoMi Oarofina mil
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sufficient to serve an appropriate level of development
consistent with a meaningful cost benefit analysis of
land development and related factors within the Horsepen
Creek basin.
Thank you.
CHAIRMAN HARVEY: Thank you.
The panel recognizes Mr. Fred Clapp,
representing the Greensboro Board of Realtors.
MR. CLAPP: Thank you, Mr. Harvey.
Members of the panel, I have been authorized by the
Board of Directors of the Greensboro Board of Realtors
to enter this statement into the public record. We will
not join the technical issues of correct line sizes.
Although the discrepancies appear serious enough that
one might question the credibility of the consultant's
entire report, we believe that all agencies involved
are properly motivated and possess the requisite
engineering skills necessary to satisfactorily resolve
that matter.
It is our understanding, however, and
reconfirmed in the meeting this afternoon, that regard-
less of the eventual line size, it is EPA's intent to
fund a sewer only to the existing population plus
hopefully, at least, providing limited additional
capacity.
hm?
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PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, Chapel Hilt (»16) 549-0696
Ratelgh (9161 832-9085
~ P. 0. Box 28163
RaMgh, North Caroline 27611
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The proposed action, we believe, will
adversely affect housing, and quite possibly the
economic stability of the community.
This summer, a special Task Force on Housing
Costs appointed by the Secretary of Housing and Urban
Development, pinpointed excessive Government regulations
as a major contributor for the current high cost of
housing.
The National Association of Realtors
estimates that over-regulation currently adds
approximately twenty percent to housing costs, or about
$9,000 to the cost of today's medium-priced new house.
»
Inasmuch as trends in existing home prices
closely follow those of new ones, such over-regulation
affects all potential home buyers.
In response to the study, HUD Secretary Harrisj
has announced, among other actions already underway,
that HUD will work with state and.local governments
for reasonable standards for land development and in
planning for an adequate supply of usable land. We
submit that the proposed action is an example of such
over-regulation and will necessarily increase the cost
of housing by increasing the minimum lot sizes and
prices and increasing the development costs for
additional streets, power, telephone and gas lines,
PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, Chapo! M
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et cetera.
The low density development proposed will
also severely restrict, if not deny, the developer's
ability to effect the economies of building cluster
houses or patio hones and attached town houses for sale
and apartment dwellings.
In the marketplace, the desirability of
residential development in our northwest section has
already been established, and we are all agreed that
eventual fufl development of the basin will occur, even
if on septic tanks.
This low density proposal, however, will
further restrict the supply and cost of land in a
market already characterized by a type and control
supply of land. Further, in such a low density
development, it will be more costly for the community
to maintain central public services, such as
transportation, schools, recreation facilities, et
cetera.
The resulting increased cost must necessarily
be borne by the taxpayers through increased property
taxes, and therefore, again, increase the cost of
maintaining a hone. At a tine in our history when low
income families have already been forced from the
private housing market, and we are rapidly pricing
VJL I PRECISION REPORTING
(Pi AND TRANSCRIBING, INC.
Durham. Chapel Hill (819) 549-66M
Ratelgh (91») 832*065
P. 0. Sox 20163
Raleigh, North Carolina v811
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middle America out of the private housing market, the
impact of the proposed action on housing costs should
not be ignored.
The most serious economic implication of the
proposed action to the entire community, however, is
the implied restriction on industrial development. We
admit the confusion and frustration about the rather
casual treatment of industrial development in the Draft
EIS. It is elementary and fundamental that sound
industrial growth is necessary to provide employment
opportunities and to expand the tax base in order to be
able to maintain a reasonable level of local taxation.
Substantial public and private investment
has already been made in the airport industrial area,
and it would be physically irresponsible not to keep
fully utilized the facilities and land provided by such
investment.
EPA's consultant states that any future
investment or development in the basin will not be
eligible for sewage funding by EPA. And the proposed
action would apparently divert all industrial sewage
to the South Buffalo Plant. Yet the consultant claims
that industrial development is limited primarily by the
size of the collector and outfall sewers in the South
Buffalo basin, and further, that systems modifications
CT] PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, Chap* HHf ffl*) MMMN
~ «££
North Cwofctt 27*11
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necessary to sewer future industrial growth and the
airport will require at a minimum replacing the major
collectors and outfall sewers to the South Buffalo
Treatment Plant.
The cost of such action may well be greatly
in excess of that of the Ilorsepen Creek interceptor line
itself, and will be presumably entirely the expense of
the community. Indeed, the metro plan accepted did not
provide for^any specific collection interceptor system
expansion.
The proposed action, therefore, appears to
directly and indirectly impose extreme limitations on
the community's ability to provide for a desirable
expansion of industry. The adverse impact on housing
and industrial development resulting from this proposed
action are not in the best interest of the community.
We submit that the community will best be
served by the selection of Alternative IF, which
basically would provide full sewer service to the entire
basin. We are not insensitive, to the potential "hazards
of development within any watershed. However, we are
not persuaded by the EIS that the low density disbursemen-j
of housing and the addition of 2,500 septic tanks to the
basin is the proper way to handle development.
The EIS addresses itself to the introduction
1FST
Jftij
PRECISION REPORTING
AND TRANSCRIBING, INC.
Durftam, Chapel Hill (919) 949-0899
RaJtigh (919} 83240S5
~ P. 0. Box 39163
Raltlgh, North Carolina 37911
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of pollutants intobLake Brandt, but it is silent
concerning the technology of removing pollutants by
water treatment methods. Further, the EIS on the one
hand addresses itself to lead loadings in Lake Brandt
from automobiles associated with development in the
basin, and yet, on the other hand, ignores existing
Government regulations that require us to drive less
efficient, more expensive automobiles that are restricted
to the use of unleaded gasoline.
the basin has been questioned. Yet the EIS concedes
that:
". . .Many other measures required to
promote orderly development of the
Horsepen Creek area and preserve the
water quality of Lake Brandt already
exist."
Indeed, one condition of the grant is that
an erosion and sedimentation control plan must be
submitted to EPA for approval. County regulations
dealing with control of stormwater runoff are under
study and awaiting finalization of state plans for such
control.
The Board of Realtors believes that the
county and city can and will implement adequate measures
The community's ability to manage growth in
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for orderly development. The: Board will support and
cooperate with such reasonable measures as may be
required. We stand firm in our position that local
governments are the proper authorities to control land
use and development regulations within local bounds.
We further submit that the coummunity must
finally recognize the fact that Lake Brandt cannot be
indefinitely counted upon as a major water supply source,]
and that within the twenty years design period, we must
look beyond our present water storage system for an
adequate water supply.
On balance therefore, we cannot support the
proposed action as being in the best interest of the
community. And we urge the Director to reconsider the
recommendation. Thank you.
CHAIRMAN HARVEY: Thank you, sir.
The panel chooses to recognize Dr. Paul Lutz,
representing the Guilford County Advisory Board for
Environmental Quality.
DR. LUTZ: Mr. Harvey, apparently
the EIS Statement is like a big fruit basket. One can
piak and choose what one likes and ignore the rest.
Apparently that is what has gone on heretofore.
There is a temptation for me to do exactly
that way; that is, pick and choose what I want to talk
PRECISION REPORTING
AND TRANSCRIBING, INC.
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about in the EIS and let the rest alone. I think v
rather than getting into that argument, I would simply
like to read my prepared statement and then sit down.
Ever since its inception in 1972, the
Guilford County Advisory Board for Environmental Quality
has considered that the problems associated with water
are the most serious and urgent environmental issues
facing Guilford County now and in the future.
Our Board has ranked as a priority concern
the water quality and quantity, and this deep concern
has been manifested in many different forms in the last
six years of the history of this Board.
Since the Horsepen Creek interceptor project
directly impinges on water quality, our Board has taken
an unreasonable amount of interest in this project and
its Environmental Impact Statement. Board members have
brought considerable professional insight to bear on
many parameters of this entire project.
The Advisory Board is unswerving in its
deiligent pursuit of maintaining and even enhancing
water quality for all of our citizens. This Board has
never been against growth or development so long as
those factors did not significantly contribute to
environmental degradation.
But we are resolved in our conviction that
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water quality degradation is directly proportionate
to urban and suburban densities in the watershed. We
believe that the spreading urbanization adds numerous
exotic—that is, rare or unusual chemicals and
compounds—to water supplies in very subtle amounts.
Further, we are convinced of the real
possibilities of very severe human conditions that do
result from the protracted domestic use of water which
is compounded immediately downstream from the large
suburban areas.
There is a growing body of scientific studies
to support and validate these concerns. The spector of
the carcinogenic, pathogenic, teratogenic and nutugenic
effects induced by deteriorating water supplies is a
bleak, grim prospect for the future.
We believe that population densities in the
watershed must be kept low in order to preserve an
acceptable degree of water quality..
The Horsepen Creek project is a classic
example of the potentiality of completely degrading a
municipal water supply by developing suburban areas in
the watershed. The installation of a sewer interceptor
line in the basin will certainly foster more intense
development. More people would bring increased amounts
of a variety of exotic chemical compounds and metals that
C~3 PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, ctupti HJU (919) 540*0696
FUlalfih (919) 662-9065
IP. 0. Box 26163
FUMgh, North CtrpHna 27611
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already threaten to destroy irreversibility water
quality in all the lakes downstream.
for Environmental Quality feels that Alternative Number
5, the no action alternative, offers the best long-term
protection of water quality. And we encourage that
Alternative 5 be substituted for Alternative 2E as
recommended in the EIS.
months, consistently advocated to the Board of County
Commissioners that population densities must be kept
comparatively low in this fragile watershed. We have
strongly urged the Commissioners to support measures
that would minimize growth in the basin and will retard
runoff in the impoundment.
conditions which will reduce the chances for the water
supply to be damaged further. But the influence of the
Advisory Board to institute protective measures is
limited, and we need any additional help to regulate
density in this watershed.
Alternative Number 5 will do precisely that.
Thank you.
Therefore, the Guilford County Advisory Board
The Advisory Board has, over the past twenty
We will continue to advocate for mitigating
CHAIRMAN HARVEYj Thank you, Dr. Lutz
The panel recognizes Mr. Austin Elliott,
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representing the Environmental Action Coalition.
MR. ELLIOTT: My name is Austin
Elliott, and I am a member of the Environmental Action
Coalition.
The Environmental Action Coalition is a group
of local citizens and organizations Whose main concern is
the preservation of water quality of the Lake Brandt
reservoir. We are not against orderly growth in our
community. But we do realize that an urbanized watershedl
can be hazardous to the health of those who depend upon it|
for drinking water. Greensboro will be dependent on
Lake Brandt for many years to come.
In 1974, our group brought suit in Federal
Court against the Environmental Protection Agency, asking|
that an Environmental Impact Statement be prepared on
the Horsepen Creek project as required by the National
Environmental Policy Act.
Now the Environmental Impact Statement has
been prepared. The Radian Corporation has made several
recommendations to the EPA which we find highly
significant.
Most interesting of all is the recommendation
against funding the Horsepen project without, arid I
quote, "a more detailed long-term study of the induced
impacts to Lake Brandt."
PRECISION REPORTING
AND TRANSCRIBING, INC.
Ourhm. Chapd mi (tti)
RU«lgh t»1» wwew \
r>. o. Box m* i
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A copy of these recommendations is
attached since it does not appear in the Draft
Environmental Impact Statement.
A few months ago, we were looking favorably
upon the selection of a proposed action Alternative 2e.
It seemed to us to be a reasonable compromise,since we
do acknowledge a need for providing service for the
existing industrial wastewater in the airport area,and
the pipe sizes in the residential part of the basin were
projected to be quite small.
have claimed that Radian's calculations are in error
and that a pipe projected to be twelve inches in
diameter really needs to be twenty-seven inches in
diameter.
the carrying capacity of the pipe. While we acknowledge
that small errors in projecting pipe sizes could occur
at this stage of the process, an error of this magnitude
simply defies belief.
and the county have caused us to reconsider our support f
Alternative 2E, and we now feel that the best alternative
is the modified no action configuration which would
simply provide a new line for routing the industrial
However, since that time, the city and county
This would provide a five-fold increase in
These recent actions on the part of the city
\C~2 PRECISION REPORTING
1 AND TRANSCRIBING, INC.
Durham, Chapal Hill (910 HMM
Halaljh (919) 83M0M
~ P. 0. Box 28163
lUMgh. North Carolina 27(11
Wo** (119) 83M0M
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52
wastewater from the airport area to the new metro
plant by way of South Buffalo.
Normal growth could proceed in the residential|
part of the basin on septic tanks installed under more
strenuous regulations. We find the suggestion for
mitigated measures described in chapter six of the
Draft EIS to be excellent. But unfortunately, they
carry no real weight, since they depend on local
governments for voluntary implementation.
This is a disappointment to us, since local
policy makers have not up to now exhibited any great
commitment to the preservation of water quality or land
use planning.
We had hoped that EPA would be able to build
in more mitigating measures as conditions of the grant.
The fact that they did not is an additional reason why
we prefer Alternative 6 over the proposed action.
If the alternative selected includes pipes
which are sized to provide for more growth than the
amount permitted by the Clean Water Act, then the
Environmental Action Coalition will initiate litigation
on the grounds that this project is not consistent with
the intent of that action.
In closing, we would like to thank the
Environmental Protection Agency for providing so many
CTP PRECISION REPORTING
AND TRANSCRIBING, INC.
Durhtm. Chapel Hill (019) 549-099®
Ratoigh (919) 63*9090
~ P. O. Box 99199
ftaMgh, North Carotin* 27911
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opportunities for public input in the process of
making this decision, which is of vital importance to
all of us as local citizens.
CHAIRMAN HARVEY: Thank you very much,
Mr. Elliott.
The panel recognizes Mark Schott, President
of the Greensboro Jaycees.
MR. SCHOTT: Gentlemen, it is my
preference to give my testimony from up here in front.
I believe everybody can hear me in the back of the room.
CHAIRMAN HARVEY: Would you desire to use
the podium?
MR. SCHOTT: No, thank you, sir.
But I believe that I will be able to see your faces and
you ought to be able to see mine. And I don't think
that halfway back of the room accomplishes that
purposes. I do believe that your isolation at the front
of the room from the testimony halfway back in the room
is symbolic of the isolation that I think EPA certainly
feels currently in regard to the local leadership of
our community.
I am Mark Schott, and I am President of the
Greensboro Jaycees.
The Board of Directors of the Greensboro
Jaycees supports the development of an. adequate sewer syste
n PRECISION REPORTING
AND TRANSCRIBING, INC.
(919) I
Oft o. Box tkm
ftaM*. North OtoOm «7Vtl
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to serve the Greensboro-Guilford County community
needs and rejects the recommendations of the EPA on
economical, philosophical and practical grounds.
open land surrounding the regional airport to commercial
growth which will mean additional jobs created and
stabilized by the presence of adequate and attractive
commercial property. It should be noted that such
property is not attractive to the consuming public as
residential property, primarily due to aircraft noise
levels.
of five hundred young men who live and work now and for
the foreseeable future in this area. The second fact
has historical proof both here in Greensboro over the
last ten years and in numerous communities around the
country.
local decisions should be made by local officials who
are accountable to the local electorate. Some direction,
observation, and, if necessary, supervision should be
forthcoming from the Federal level in order to meet
standards. We do not feel that this has been the*rule
on this issue, nor do we feel that any increased involve-
ment by the Federal level of government on this specific
First, economically, the sewer system will
The former fact is important to us as a group
Philosophically, the Jaycees contend that
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¦ 55
issue or pursuant to the establishment of future growth^
policies for our community have any benefit whatsoever.
Our local governments have proved most capable of
developing such policy, and have a track record to proveitj
Thirdly, and finally, the Greensboro Jaycees
reject the EPA position on practical grounds. We are
satisfied, and I think you are also, that projections by
both studies indicate the unsuitable qualities of
Guilford County soil for widespread septic tank usage.
Additionally, it appears safe to say that the
recommended twelve-inch line'would h^ave difficulty
serving existing development and certainly could not
serve even some small additional development which is
bound to occur.
To argue that a sewer system or lack of one
is sufficient to deflect the established growth patterns
of a community is to ignore the personal, practical,
economical, and, for the lack of a better word, parochial
reasons which cause a person or a business to choose his
neighborhood.
For these reasons, the Greensboro Jaycees
support the development of a sewer system in the
Horsepen Creek basin sufficiently capable ofi serving
today's needs and the needs of tomorrow's growth.
At the same time, we desire zoning standards
C"3 PRECISION REPORTING
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Durham, ChapvJ Hill <91«) M946M
ftaMQh (019) 832-90*6
~ P. 0. Box 20163
RtMfh, North CaroHni 37611
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which will protect the Guilford Cou,nty environment
throughout the majority of the basin for residential
growth while making areas adjacent to the airport and
major transportation arteries attractive to quality
industrial and commercial growth.
This type of impact statement and pre-planning
is essential to the orderly and necessary growth of our
community if it is to safeguard the "quality of life"
which makes Greensboro-Guilford County such an out-
standing place to live and work.
More as a footnote than anything else, I
might add that I believe I am the fourth Jaycee
President to make such a statement on this matter. And
in each instance, our organization has reopened our
consideration of both sides of this issue, and right or
wrong, taken this very same position. Thank you.
CHAIRMAN HARVEY: Thank you, sir.
The panel recognizes Carolyn Allen, President
of the League of Women Voters.
MS. ALLEN: Mr. chairman, members
of the panel, I am Carolyn Allen, President of the
League of Women Voters of Guilford County.
The League has been involved with the
fortunes, and I suppose many here would say "misfortunes'
of the Horsepen Creek sewer outfall proposal since
HFST
PRECISIONREPORTING
AND TRANSCRIBING, INC.
Durban, Chap* Httl
RaMpb #*-*000
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January of 1974, when we took a stand against the
project as it was then formulated at a public hearing
on the initial Environmental Assessment Statement
prepared by Guilford County.
Our organization was sufficiently concerned
with the probable negative secondary effects on the
Greensboro water supply of urbanization stimulated by
the presence of a sewer outfall in the Horsepen basin
to join the Environmental Action Coalition as a
Plaintiff in the August 1974, suit against the Environ-
mental Protection Agency.
That suit, asking that an Environmental
Impact Statement be written on this action, began a
chain of events which this hearing represents a
culmination. It was, we believe, responsible for
slowing the timetable on construction of the proposed
outfall.
As a consequence, some have pictured the
League of Women Voters as part of a band of obstructionists
and -rabble rousers who were against motherhood and apple
pie, and, more seriously, against growth.
Let me say emphatically the League of Women
Voters does not endorse a "no growth" position. Indeed,
we believe, as do most of those assembled here tonight,
in the growth of many things: knowledge, public
C~2 PRECISION REPORTING
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OwtMffl, Ctwpti HHI (019) 64M6M
RfttoiQh (919) 832-9096
IP. 0. Box 89163
RaMgh, North Carolina 97911
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participation in government, economfic strength, the
health and well-being of all citizens, and the improve-
ment of our social and physical environment.
with another, the League of Women Voters does contend
that caution is necessary in relation to short-term
gain. When short-term gain may jeopardize a resource
without which we cannot long survive—water that is fit
to drink—then delay in this project and in any other
of similar nature is essential.
world, the size of which we have only recently begun to
appreciate. During the months since the inception of
this effort by the county, more scientific data has
accumulated regarding the effects on water quality of
non-point sources of pollution, especially that
associated with urban areas.
deleterious effects of heavy metals and a host of
chemical compounds which are being found in city water
supplies for the first time. Water quality monitoring
techniques are being extended to include new substances
which had not previously been recognized as hazards to
human health.
But where one good or desirable end conflicts
Urbanization extracts a toll from the natural
More information is at hand regarding the
The long-term debilitating consequences of
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some chemicals which accumulate in living tissue N
have also been identified. Perhaps, most importantly
for Guilford County, the Commissioners have, during the
past four years, taken certain steps which lay the
groundwork for a satisfactory growth management plan.
Much remains to be done, but the stated policies of the
Guilford County Board of Commissioners acknowledge the
need for land use planning to protect fragile environ-
ments .
A "Land Use Goals and Policies" statement has been
adopted which indicates a concern for balancing
development and environmental protection. Zoning and
subdivision ordinances are in effect which should, if
consistently applied, lead to a satisfactory population
density and appropriate construction and design
safeguards in the Horsepen basin.
enforced, will be crucial in sustaining satisfactory
water quality as development in that area proceeds.
Many of these policies have evolved in the last four
years.
now favors Alternative 6, modified no action, with its
provisions for handling industrial effluent arising in
An Open Space Program has been initiated.
The County's septic tank ordinance, strictly
For these reasons, the League of Women Voters
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southwest portion of the basin and'maintaining the
existing collection system in the eastern sector of
the basin. Low density residential development will
proceed within the statutory guides described above.
As suggested in the excellent section of the
°raft EIS on "Mitigating Measures," a system for handling
storm water runoff should be initiated and the water
quality monitoring system expanded. The inclusion of
the County in North Carolina's Wastewater Management
208 Plan, as indicated in Secretary Lee's letter of
June, 1978, *ko Mr. White,„Region. IV, EPA Director, will
also provide guidance to several governmental units
facing development in watersheds. This problem is
certainly not unique to the Greensboro water supply
lakes.
Finally, since the inception of the Horsepen
Creek project, action has been taken to extend sewer
service to the northeast of Greensboro. More dense
development in this area made possible by the availabili
ty of sewer lines will relieve Somewhat the pressures
for growth to the northwest.
In sum, the League of Women Voters believes
that the knowledge accumulated and the actions taken
by county government during the past four years have
increased the likelihood that we nay proceed with
PRECISE REPORTING
"AND TRANSCRIBING, INC.
- Oldham, Chap* MN
Ratolgh (MtltaMMS
*»»>•M»-«ii i
Matt* OMUwtyfM.-
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managed growth in the Horsepen Creek basin, and not
in the process, "kill the goose that laid the golden
egg" by irreversibly polluting our water supply.
Thank you.
CHAIRMAN HARVEY: Thank you.
The panel recognizes Jack Jezorek.
MR. JEZOREK: I am Jack Jezorek, and
I am speaking as a citizen of Guilford County.
A decision on the Horsepen Creek interceptor
sewer has been a long time coming. One beneficial
aspect of this slow process is that we in the county
and EPA have had time to sit back and look at the
project a little more closely in order to judge its
merits.
For my part, I am just as convinced as ever
that this project will do more harm than good; that is,
the cost benefit ratio is unfavorable.
The more we learn about the long-term
effects of consumption of water with low levels of
contaminants, the greater should be our resolve to do
everything possible to maintain the purity of our
water supply.
Unfortunately, large scale development in
the basin will work captive to that good. Hopefully,
the fact that EPA has recommended a sewer to serve
PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, Chapal HUI MtOMe
fUMIfh (019) 832-9068
~ P. 0. Box 28163
RaMefc North Carolina J781)
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existing needs plus modest growth, means that they
see the necessity for limiting growth in the watershed.
It might be noted here that the 1972, Federal
Water Pollution Control Act limits the use of Federal
funds to modest growth plus existing needs. This money
is not designated by the Congress as a growth stimulator.
Growth limitation is the important point,
however. The sewer of and by itself will not cause
rapid growth in the basin. County policy is what
determines this. Expansion of the tax base and the
now shop-worn .platitude that "people want to live out
there" are not valid reasons for county policy to opt
or complete basin development.
We must take a prudent approach, because if
we develop heavily and then find our water supply
degraded, there is no easy remedy* Purification costs
are astronomical.
However, should we limit growth and later
find an inexpensive method of purifying our water, or
that long-term effects were not as severe as now
believed, we can always develop more density later.
My own position remains that the no action
or modified no action alternatives are most desirable.
I can live with the modest growth alternative, 2E, if
I were to see a resolve on the part of the county to
r-n PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, Chapal Mil (#1») M»MM
RaMgh (««) 6SM0M
p. o. Box wn.
taMgh. North 87911
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operate in this limited growth spirit.
But should the county persist in planning
a. need for a bigger or a second pipe so that development
can proceed fullspeed, then I cannot support this
alternative.
The suggestions made by citizen groups and
individuals are a good place to start in minimizing the
negative impact of development. I recommend that the
county seriously consider implementing these and other
suggestions to preserve the quality of our drinking
water and take strong measures to steer growth to the
east of the city.
Thank you.
CHAIRMAN HARVEY: Thank you, sir.
I think it is appropriate at this point to
take a brief recess. I intend to recess for approximate
ly five minutes. So, we will stand in recess, then,
until 9:15. Thank you.
(A brief recess was taken.)
IH3U
PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, Chtp«l Mil (919)
RaMOh (919) 832-9099
~ P. 0. Box 89199
RaMgh. North OaroUna 87911
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FURTHER PROCEEDINGS 9:15 p....
CHAIRMAN HARVEY:
This hearing will come
to order.
The panel recognizes Mr. Tom Duckwall.
representing the Audubon Society.
MR. DUCKWALL:
Thank you, Mr. Harvey.
Mr. Harvey and other members of the panel
actually I am Conservation Chairman for the Local Chapter
of the National Audubon Society.
organization that since the earlier centuries,
has solicited the conservation of all wildlife and other
natural resources. We work to eliminate unnecessary
pollution, unwarranted destruction, of essential wildlife
habitats, the premature extinction of species, and the
waste of our natural wealth in all its forms.
range problem thete may be controls or solutions that
appear adequate, but in reality they are shortsighted
and help to create problems more serious than those we
are supposed to deal with.
important step in working to a solution. In a situation
of this type, we have to start by recognising that the
The National Audubon Society is an
We recognize and expect that for any long-
We are assembled tonight to carry out an
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V 65
fundamental question is quality of the water supply
in a long-tern basis for the city and the surrounding
areas, rather than how much or what kind of growth an
area should have.
So, if there is a real possibility that some
activity will reduce that water quality significantly,
our plans must either compensate for or reduce that
activity to an acceptable level.
It is no secret that when forests and fields
become suburban and industrial real estate that normal
filtration and absorption functions of the earth is
both prevented by buildings and pavement and made more
difficult by the presence of grease, gasoline, oil,
battery acid, soot and litter. This will occur whether
or not the land were near a municipal water intake
point. But obviously when this is the case, the choices
are much more significant.
For these reasons and because of the cautious
attitude toward development into the vicinity of any
airport, we recommend that no action be taken that would
in the long run tend to create waterfall problems by
increasing the urban-type runoff immediately upstream
from Lake Brandt.
If this means that certain types of
construction must be carefully restricted, we believe
r-J PRECISION REPORTING
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Durham, Chap* HUI (919) 549-06*
RatolSh (919) 832-9066
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1 I this limitation should be accepted by all concerned
2 I in the interest of fellow citizens, and that sewage
3 I planning should be consistent with the same.
4 | Thank you very much.
5 | CHAIRMAN HARVEY: Thank you, sir.
6 | The panel recognizes Patricia Lutz, represent-
7 | ing the Sierra Club.
8| MS. LUTZ: I am Pat Lutz, and I
am Chairperson of the Piedmont-Highpoint Sierra Club.
The Sierra Club has been on record opposing
this interceptor line to the Horsepen Creek basin since
the initial proposal.
After the Environmental Impact Statement was
published, we felt that our concerns and our objections
were confirmed. In fact, the water quality is rapidly
deteriorating with the amount of development
presently found in the basin. The effect of septic
tanks,once thought to be the principal source of
pollution in that basin, have been shown to be minimum.
Surprisingly, the principal sources of
pollution have been due to urbanizations processes
itself. Lake Brandt carries a balanced eco-
system at this time with very little ability to absorb
additional pollutants. Any change in the present land
use pattern will destroy this balance, bringing on
PRECISION flEPQRtlNG
AND mANSCWIlilNG, INC.
(Ml i
Raft** ptm
Op. a 8m mm-. . ,
RdMih. North (Siroiliu
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eutrophication of the lake and thereby making it
unsable for a drinking system.
The pollutants in this case are the nitrogen
and phosphorus levels. The concentrations of these
chemicals will be increased as the basin becomes
urbanized. The eutrophicationis being held in check
now by sedimentation from agricultural lands. And while
sedimentation itself is undesirable, without it Lake
Brandt wouldn't be here today.
found that the concentrations of lead in Lake Brandt
exceeded the safety regulations for public drinking
watet supply. These lead concentrations are a direct
result of urbanization and the transportation systems
that must accompany it.
exposure, even in moderate concentrations, can cause
chronic illnesses and perhaps death. The concentrations
in our water supply are already dangerous, and further
urbanization would bring more of these exotic chemicals
into the water supply.
stated in the Environmental Impact Statement is almost
criminal, and the effects will be felt by ouzr citizens
for years and years to come.
The Environmental Impact Statement also
Lead is a cumulative poison and long-term
To ignore this concept which is so clearly
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68
We have highlighted only a few of the
problems that concern us about this proposal. But we
feel that these illustrate our position.
The lasting effects of a mistake at this
juncture in time makes this proposal something more than
a mere interceptor line. And for that reason, we
recommend that Alternative 5 or 6 be accepted.
We also urge the EPA to accept the data
reflected in.the Environmental Impact Statement in their
decision making process. These data, gathered by an
unbiased study group, with no contractual agreements in
Guilford County, would seem to be the most credible.
Our water supply problems are already
legendary. We must not destroy what we have. The
Sierra Club has operated for many years with a motto
that is very appropriate for this issue:
". . .Not blind opposition to progress,
but opposition to blind progress."
CHAIRMAN HARVEY: Thank you very much.
The panel recognizes Mazie1-J. Levenson.
MS. LEVENSON: Mr. Chairman and
members of the panel, I speak as a private citizen; one
who has been interested in wat&hing our county grow and
the many improvements being made in it for over twenty-
five years in this area.'
FWBOSlONREPORTf^Q
NND TRAfsKfceSl^NG, INC.
sws^sr1*"-
Ja
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I, too, take a great deal of pride in the
policy of the people that are attracted to serve on our
City Council and on our County Government and also high
caliber professional staff which we have.
So, it is knowing some of our staff and some
of the problems that they have been working with that
I have become interested in this problem. I would first
of all like to say that as citizens, we are most grateful
to the EPA for the studies necessary to compile this
particular Environmental Impact Statement, for it points
out the interrelationships between water quality and
urbanizing lands adjacent to the water reservoir.
This document plainly states that it is not
possible to have a future population of 18,000 in the
Horsepen Creek basin without deterioration of the Lake
Brandt reservoir*
How, we know that the last reservoir which
Greensboro completed took 13 years from its inception
to its completion. And it is with that in mind that
we do not feel that we can see the quick deterioration
of Lake Brandt.
This is especially so since we are not aware
that either the county government or city government
are presently acquiring lands for new reservoirs.
We are glad that considerable space was
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devoted in this document to measures which can be
taken to lessen the impact of urbanization on the water I
quality in Lake Brandt. I
I have read a number of pamphlets and
bulletins on water quality, but never have I seen it I
indicated so plainly which measures could be taken to I
lessen the impact of urbanization on water quality. I
To me, a lay reader, I thought this was laid out in I
very explicit terms. I
W6 know there are many adverse effects in I
increased development in the Horsepen Creek basin on I
Lake Brandt. The Lake will have a heavier load with J
metals and phosphorus. The increased runoff from I
driveways, highways and yards will bring more sediment J
into the Lake and more diverse pollutants. J
As more organic material washes to the Lake, J
problems of odor and taste will occur. But this I
deterioration in water quality can be lessened by I
instituting certain preventive measures as outlined in I
this Draft for the Environmental Impact Statement. I
First, the water monitoring programs fojf I
Horsepen Creek and Lake Brandt must begin. We* have not
had such monitoring systems. Such a monitbring system
would give early warning of problem areas where
pollutants will be entering the streams which feed Lake
nrY IL J PRECISION REPORTING
ni lri ANDTRANSCR181NG, INC.
n ( OurtHffl, tUmxl WW EHMWfcMI
irl HI HMmmoMii ,
II I u I n p. o: •« attM
—11 K n llinil l n«t»wi. wm«i CBBMii areti -
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Brandt, and would allow preventive measures to be
taken early.
storm management. And this is in spite of the fact that
storm management regulations were introduced about a
year and a half ago, but were defeated. So, we now
learn that stormwater regulations are needed to lessen
the pollutant loads into the reservoir in order to slow
down the runoff water and to allow more infiltration
into the ground.
ordinances should always be done, and we hope has been
done in this county. But this document outlines even
more forcefully that strict enforcement of the septic
tank ordinance must be enforced to see that the lands
which do not percolate properly are denied permits, and
that septic tanks are properly located and installed.
health hazard exists. With the Horsepen Creek sewer
and the watershed, future tie-ins to.the interceptor
must not be allowed to exceed the capacity of the design.
This must require legal descriptions. I am not aware
that any legal descriptions would have to be written in
for this specific interceptor.
Guilford County has no regulations regarding
Strict enforcement of the septic tank
When overflow sanitary sewage occurs, a
This documents makes reference many times to
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the necessity for good land use controls in areas
which are becoming urbanized. We commend our Guilford
3 County Commissioners and the Planning Department for
4 their policy guidelines under the title "Land Use Goals
5 and Policies."
6 This publication sets forth excellent goals,
7 but to implement these goals requires both adequate
8 staff and money. Presently the Guilford County planning
9 staff is lacking personnel in several top positions.
10 This shortage of professional staff jeopardizes the
11 accurate supervision and coordination of planning
12, functions.
13 But more importantly, a shortage of staff
14 means a lack of time for planning for future land
15 development. Under Guilford County's Open Space
16 Program, it is most important that monies continue to
17 be appropriated for the environmentally sensitive areas.
18 Some of these areas will be in the watershed, and their
19 careful management will contribute to the maintenance
20 of good quality water.
21 This Draft for the Environmental Impact
22 Statement for the Horsepen Creek interceptor clearly
23 states that adequate land use controls are essential
24 for the development of any alternative which is selected
25 for the development of the Horsepen Creek basin.
r—] PRECISION REPORTING
AND TRANSCRIBING, INC.
Durham, Chapel Hill (016) 649-0698
ftalalffh (919) 832-9065
IP. 0. Box 28163
Rafalgh, North Carolina 27611
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Inasmuch as Alternative 2E would allow
improvements in the present situation, yet slow down
urban growth, I would favor, this Alternative. Again,
we thank the EPA for this document and the mitigating
measures outlined for protecting the Lake Brandt
reservoir and its water.
The panel recognizes Frank York, President
of the Greensboro-High Point Homebuilders.
been some very good speeches made on both sides tonight,
so I will make mine short.
I am President of the Greensboro-Highpoint
Homebuilders Association, which includes Guilford County.
This Association feels that it is very important to have
an adequate sewer line in this basin for future growth,
because there will be houses built in this area.
There are going to be babies born, and we
have got to have housing for them. It is our opinion
that houses built in this area served by this outfall
would be better for the environment than septic tanks.
We urge you to consider the city and county's
request for adequate lines to fill these needs.
Thank you.
Thank you
CHAIRMAIJ HARVEY:
Thank you
MR. YORK:
Mr. Chairman, there have
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X 74
CHAIRMAN HARVEY: Thank you, sir.
The panel recognizes Hal B. Lewis.
MR. LEWIS: I requested to be last.
I hope this is the last speaker.
CHAIRMAN HARVEY: Not quite, sir.
MR. LEWIS: Mr. Chairman, members
of the panel, ny name is Hal Lewis. I appear before you
as a beleagurecl poor taxpayer, and somehow I feel like
whatever happens here tonight, I am going to pay for it
way or the other.
I support your conclusion of 2E for a twelve-
inch line. Now, I gave you a prepared statement which
I won't read from. I would like to comment on something
which hasn't been brought out adequately tonight, and
that is the reason for the twelve-inch line.
If you refer to the paper, the second reason—
I shall read:
". . .interceptors are being built so
as to service potential growth far into
the future; the median design year of the
projects reviewed was over 50 years, with
a mean of 105 years. In one case in fact,
the interceptor would support growth for
over 20 00 years based on past growth trends.
Furthermore, assuming that demand for
PRECISION REPORTING
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Durham. Clwpcl Hill (919) 6404098
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%
2!
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sewage services grows at 3 percent a
year and future construction costs
double, the study demonstrates that
building for a 25-year design period
is more economic for a 50-year design
period."
In other words, it cost more to build for a
long range than it does to put in two parallel lines•
Now, this is a point we have all missed here tonight.
Everybody is pleading for a large line for the future.
And as a taxpayer, I am here to tell you that I have no
obligation to the citizens residing in this county in
the year 2025. I believe in pay as you go.
If the citizens in 2025, want to build a
16-inch sewer line, let them build and pay for it. So,
I will support you in your 2E Alternative.
Thank you.
The panel recognizes Roger Sekadlo, Executive
Director, of the Airport Authority.
MR. SEKADLO: Mv o i ^ ^
Mr. Sekadlo has left.
I am Stanley Frank, Chairman of ¦ *.
, wiairraan of the Greensboro-High Point
Airport Authority.
My remarks are going to be brief. I would
like to say that to my knowledge Radian has never been
CHAIRMAN HARVEY:
Thank you, sir.
¦pC"! PRECISION REPORTiMrs
|| I _ bT*" HMOU
r. 9. BOX 2*1*8
Cattiina aren
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to the airport to get any data from us. I have little
technical knowledge. However, I can say no one can
control the air traffic and usage by the public, and
that is quite evident by the growth that we have
in the last year to year and a half in air traffic
throughout the United States.
We will need sewer service without a doubt.
Certainly a system that provides for little or no
growth is inconceivable and a waste of funds.
I urge that a plan be approved that will
provide for reasonable and orderly growth. Certainly
the Horsepen Creek line properly sized will meet the
above needs.
The Airport is growing at the rate of about
13 percent per year. We anticipate a flow after the
new terminal, which is being constructed, of more than
60,000 gallons per 4ay, certainly by 1985. And by
1995, we estimate 153,000 gallons per day.
The Airport's needs must be properly provided
for. And certainly you should take this into
consideration.
Thank you.
CHAIRMAN HARVEY: Thank you, sir.
Is there anyone else who desires to offer
comments to the panel? If you would, please go to the
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Ralalfh, North Carolina 27611
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~\^77
microphone and state.your name and whom you are
representing, if anyone, please?
MR. SHAW: Sir, my name is Ray
Shaw. I am with the City of Greensboro. I do not have
a prepared presentation. I would just like to make a
couple of comments which we have alluded on several
occasions tonight, the lead loadings in Lake Brandt.
I am afraid that we have been maybe a little
bit guilty of picking in the fruit basket what we wish
to come up with, and if I might also be granted that
privilege, I would like to pick in that same fruit basket
for a few items from the Radian report.
I would like to set for once and for all the
feeling of people to rest that Lake Brandt is not filling
up with lead. Fish are not going to the bottom as a
result of excessive waste and taking on lead that is in
the waters of Lake Brandt.
The Radian report quite clearly states that
a reliable estimate of annual lead loading to Lake
Brandt under existing conditions could not be obtained
due to the high variability of the measured concentration^
They do go on to say that by their methodology
they do estimate lead could increase approximately
twenty percent over the leveis which were measured during
their study.
PRECISION REPORTING
AND TRANSCRIBING, INC.
Dl"h'm, Ch»p«l Hill It19) MMOM
nawgh um au-Mu
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DaWgh, Noah CuoIIm 2T8H
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78
In addition to that, they also make the
statement that it is likely that the greater developed
acreage that is hypothesized in the septic tank scenario
will produce higher lead yeilds than the sanitary sewer
scenario.
However, with the existing data, it cannot
be conclusively stated that there will be any significant
difference in lead yields between the two types of
development.
In addition to that, this report completely
ignores existing technology which is available on the
capability .of water plants to remove heavy metals. This
technology is available from EPA in a very fine document
that has been out, as far as I know, approximately two
and a half to three years.
They do not adequately deal with the fact
that )bhe lead that is in the lake in all probability is
being recycled from the bottom deposits during
chemically reducing seasons of the year which occur
annually, nor do they adequately deal, although
it has been alluded to tonight, to the. fact that
probably in another five to ten years we will, all be
driving automobiles with no lead in the gas. And if
the source of the lead,which they state they do not
know where the source of the lead or the arsenic comes
raw
iu.c
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Durham, Chapel HOI (919) 549*0698
RaWflh (919} 632*9066
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Rttolgh, North Carolina 27911
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. __ \ 79
from, if it is indeed related to transportation, then ^
I think that we can feel that within the next few years,
irrespective of development, if the source of lead does
come from leaded gasoline, there would be eventless lead.
The samples which have been taken from our
drinking water supply, analyzed by the city, analyzed
by the Environmental Protection Agency, and analyzed
by the laboratories of the State of North Carolina, have
never indicated any lead concentrations in excess of
those outlined in the Interim Primary Drinking Water
Standards.
Thank you.
CHAIRMAN HARVEY: Thank you very much, Mr,
Shaw.
Is there anyone else who wishes to offer
testimony to the panel?
(No response.)
CHAIRMAN HARVEY: Apparently not.
I wish to thank everyone who testified this
evening for their testimony. Your comments will be
carefully considered and responded to in the Final
Environmental Impact Statement.
Your comments will be a major determining
factor in the project alternative to be recommended for
funding, as both the Environmental Protection Agency and
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1l ^
JT JLI-t
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the state place great importance on the desires of the ^
community.
With regard to procedural matters, I wish to
remind you that the record will remain open for an
additional fifteen days if you wish to submit further
written comment.
The final EIS will take a minimum of 60 days
to complete. Upon completion, the document will be
filed with the Environmental Protection Agency, Office
of Federal Activities, and made available to the public.
Those of you who have commented tonight or
submit comments will receive a copy of the Final
Environmental Impact Statement.
Again, the Environmental Protection Agency and
the State of North Carolina wish to thank you for
attending this public hearing and participating in the
process.
I extend my personal thanks for all the
kindness shown to the members of EPA1s Region IV staff,
and I am sure Mr. McRorie joins me in that. We
appreciate it very much. Thank you and good evening.
(Whereupon, at 9:50 p.m., the proceeding in
the above-entitled matter was closed.)
W
Iffil
T PRECISION REPORTING
AND TRANSCRIBING, INC.
Llo
Durham, Chip.! Hill <*t»l MMM«
Ralalgh (919) 632-9045
P. O. BOX 281&3
JMdgft, North Carolina 27(11
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CERTIFICATE
I, Jo B. Bush, do hereby certify that
the foregoing pages 1 through 80 are a
true and accurate record of the
proceedings on Monday, November 20,
1978, in Greensboro, North Carolina,
for the public hearing on the
Greensboro-Guilford County, North
Carolina Horsepen Creek interceptor.
OFFICIAL REPORTER
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