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State Clearinghouse <br />March 16, 2009 <br />Page 2 \ <br />This is flatly wrong. A large (about four acres), important vernal pool <br />system-a type of protected wetland-is located under and immediately adjacent <br />to the actual proposed building footprint and cerkainly well within the area to be <br />graded for access to the building by heavy trucks. See Exhibit A, attached; <br />compare EA Exhibit A, "Site 056 Plan Layout:' This vernal pool system is directly <br />connected to navigable waters of the United States, and so are wetlands <br />protected by Section 404 of the Clean Water Act and Corps of Engineers <br />regulations. See Exhibit B, letter of certified wetlands delineator. In addition, <br />"the hydric soils and hydrophilic vegetation at the site, typical of the upland <br />wetlands of the Piedmont, appear to extend far beyond the water surface <br />because of the flat topography. An abundance of aquatic life was observed at the <br />site including frogs, frog eggs, and salamander eggs as well as other wild life <br />such as turkeys (the remains of a kill), bobcat scat, turtles; and deer and raccoon <br />foot prints." Exhibit A, Letter of M. Hughes, P.E. In fact, nearly the entire site is <br />composed of the lignum soil series, which is partially hydric and characterized by <br />water within 12 to 30 inches of the ground surface. <br />This misrepresentation regarding wetlands is very important. This <br />misrepresentation would be important in any EA because of the environmental, <br />~~ ~ - legal, and project feasibility impacts of wetlands being present on the site. It is <br />_~ ~ , <br />even more important to this project because the presence of wetlands on a site <br />was an exclusionary criterion in the site selection process. See Exhibit C, <br />Exclusionary Criteria Chart. That is, the presence of these wetlands on this site <br />should have excluded this site from any consideration for the location of this <br />project, under the county's own standards. <br />ALTERNATIVES ANALYSIS <br />Failure of the EA to discuss alternatives <br />The Environmental Assessment Guidelines promulgated by the <br />Clearinghouse require that the alternatives analysis in an EA "discuss all <br />reasonable alternatives to the proposed project, including the alternative of no <br />action:' <br />This EA discusses only one alternative. It fails to discuss even a <br />reasonable range of alternatives, much less all alternatives.. There is no <br />discussion of the `no action' alternative. The only alternative discussed is waste <br />to energy. <br />