Friends of Bolin Creek sent these comments on UNC’s application for Carolina North for a U.S. Army Corps of Engineers Individual Permit, and a 401 Water Quality Certification from the N.C. Division of Water Quality.
Impact on Bolin Creek from Carolina North project. The application seeks to address impacts on streams and wetlands outside the development footprint with the goal of minimizing those impacts. Yet many of the transit improvements and additional impervious surfaces of the new campus will cause significant impacts to the Bolin and Booker Creek watersheds. For example, Stream 5A is described as inconsequential, but is a high value tributary as it flows toward Bolin Creek. We are concerned about the effectiveness of stormwater facilities to actually prevent increased flow through protected buffers and into perennial and intermittent streams such as 5A. The Jordan Lake rules mandate that even activities outside the protected buffer are not allowed to cause hydrologic impacts to the buffer and stream. Stormwater facilities should exceed minimum standards to ensure that buffers and streams are protected even in unusual storm events.
The University further states that throughout the permit application process, the University communicated with other agencies and with the Town of Chapel Hill and OWASA. We are concerned that the Chapel Hill Storm Water Management utility has not assessed or commented on the many miles of streams affected by Carolina North.
Waste water reuse project. The project is described in the application as creating unavoidable impacts. A water reuse project, while laudable, is not necessary infrastructure and would come at a high financial cost while causing damage to area creeks. The route of a force main on C-9 would unnecessarily cross and disturb a main section of Bolin Creek. 14 B is an example of a stream that originates north of Bolin Creek, flows through a forested upland area to a culvert under Estes Drive, which would also be impacted by this project. Even if this expensive and voluntary project were to be undertaken, locating the pump station as sited on map C-9 is not the only feasible location.
Sewell School Road Bikelanes. The application states that two off-road bike lanes will be built along Seawell School Road. This appears to be inconsistent with the statement on page 36 of the application that states that the Town of Chapel Hill approved a minor modification to the Development Agreement to allow placement of a sidewalk and bicycle facilities along the east side of Seawell School Road, thus reducing the impact to perennial and intermittent streams. We want the assurance from the applicant that approving this permit will retain the ability for the University to build at an off-road bike path along Seawell School Road as described in the Development Agreement.