Damn the Deep...and the Haw and the Yadkin

Interbasin transfer concerns have “ fallen through the cracks “.

The 1990 Draft EIS for the required state Interbasin Transfer Permit drew harsh criticism from the N.C. Water Quality Section Assistant Chief Trevor Clements :

The report does a very poor job of addressing potential water quality
impacts associated with the proposed lake project. The influence of the
impoundment on the present flow regime, and corresponding water
quality both in the project area and downstream are not discussed. Expected
pollutant loadings to the lake are not summarized for the basin and no attempts
to predict ( i.e. , model ) water quality within the basin were made.

Page 59 of the “Environmental Consequences “ states that the minimum
release will equal the 7Q10 flow. However, no mention is made of how
often minimum release events will occur. A 7Q10 event reflects the lowest
seven consecutive day average flow that is expected to occur only once
every ten years. Will this event under the proposed project occur more
often? If so, what are the implications of creating more frequent critical low
flow periods thereby placing greater stress on the downstream receiving

The impacts of constructing another dam on the Deep River, allowing the transfer of 28.5 mgd of Deep River water to the Haw River and the 2.0 mgd transfer to the Yadkin River have never been adequately addressed.

The N.C. Environmental Management Commission approval of the 1991 Interbasin Transfer Permit was contested in N.C. Superior Court . In his May 12, 1994 decision, The Honorable Dexter Brooks, Superior Court Judge found: “ The EIS for the proposed Randleman Lake is inadequate as it did not fully show and analyze all of the impacts of the proposed project ...”2

The findings of the only judge to rule on the the adequacy of the information used to approve the Interbasin Permit have “ fallen thru the cracks “. The 1997 U.S. Army Corps of Engineers Draft EIS states : “...the specific impacts of interbasin transfer associated with the proposed project have already been judged acceptable by the State of North Carolina.”3

The EPA has concerns on the inadequacy of the latest Draft EIS ; asking some of the same questions asked by the N.C. Water Quality Section, in 1990. The EPA questions whether the Deep River has been modeled downstream of the proposed impoundment for the effects the reduced flow would have on dissolved oxygen and what changes to the Deep, Haw, and Yakdin basins ecosystems will occur.4

EPA wants to know how the wetlands, endangered and threatened species in the three basins will be effected.5 For the current average, high and low flow conditions, relate projected flow conditions. The effects of the interbasin transfers and the habitat of endangered species should be characterized6

In addition to numerous other concerns, the EPA questions the projected flow reductions data for the Deep River.7

EPA 1997 Draft EIS comments state:

In conclusion, EPA has a number of misgivings over the feasibility
and suitability of the proposed project to provide a safe water supply
that will meet the needs and maintain the health of future generations. 8

1 MEMORANDUM, Randleman Lake Draft Environmental Impact Statement, January 23, 1990,p.1,2.

2 Report of Proceedings, Proposed Reclassification of Segments of the Deep River (Proposed Randleman Reservoir) Public Hearing, September 1, 1998,p.H-35.

3 Draft Environmental Impact Statement, Randleman Lake, Guildford and Randolph Counties North Carolina, June 1997, US Army Corps of Engineers, Wilmington District,p.3-22.

4 Draft Environmental Impact Statement on Randleman Lake, Guilford and Randolph Counties, North Carolina; June 1997, Phyllis Harris, Regional Council and Director, Environmental Accountability Division, United States Environmental Protection Agency Region 4, October 6, 1997, p.9.

5 Ibid.p.8.

6 Ibid.

7 Ibid.p.9.

8 Ibid.p.3.