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James L. Conner II <br />Attorney & Mediator <br />March 16, 2009 <br />State Clearinghouse <br />N.C. Department of Administration <br />1301 Mail Service Center <br />Raleigh, NC 27699-1301 <br />Re: SEPA Environmental Assessment <br />ORANGE COUNTY WASTE TRANSFER STATION <br />Received Date: 02/20/2009 <br />SCH #:09E00000228 <br />Dear Clearinghouse: <br />I offer the following comments on this Environmental Assessment on <br />behalf of my clients, a group of residents who live, operate businesses, and work <br />farms in Orange County near the.,prgposed_groject.~.. ,...:~ . <br />.. ~ .,.. - <br />The Environmental Assessment submitted for the Orange County Waste <br />Transfer Station is inadequate under the standards established by law and <br />regulation, for all the reasons set out in this letter and its attachments. In order <br />to meet the requirements of law, the EA should be rewritten and resubmitted for <br />comment. In addition, the EA itself when read with these comments establishes <br />that the proposed project would cause significant environmental impact and that <br />an Environmental Impact Statement (EIS) should be prepared. <br />A thorough list of errors, omissions, and misrepresentations is attached to <br />this letter as Appendix A. In the interest of brevity and readability, this letter will <br />address only the most important problems with the EA. <br />WETLANDS. <br />The EA represents that the nearest wetlands to the site are nearly a half <br />mile from the proposed facility. EA § 3.4. The EA also represents that "there are <br />no wetlands within areas to be disturbed by the project construction or operation <br />of the transfer station:' EA § 4.4. With 51 words, the EA dismisses wetlands as <br />being of no concern. Id. <br />311 E. MAIN STREET DURHAM NORTH CAROLINA 27701 <br />1001 CANAL DRIVE CAROLINA BEACH, NORTH CAROLINA 28428 <br />PHONE: 919-749-9943 ~ FAX: 919-688-2426 <br />