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Efland Station's Impacts on All Three Imperiled Species
<br /> Development and related water pollution are the first threats listed by the Service as threatening
<br /> the continued existence of the Carolina madtom,Neuse River waterdog, and Atlantic pigtoe. 83 Fed.
<br /> Reg. 51,574 (Oct. 11, 2018); 84 Fed. Reg. 23,649 (May 22, 2019). With 70 acres of impervious
<br /> surfaces, the Efland Station would generate tremendous amounts of rainwater runoff, which would
<br /> sweep considerable amounts of pollution away from the facility and deposit some of it, unfiltered and
<br /> unmitigated, directly into Sevenmile Creek. With 120 fuel pumps, the facility's parking lot will
<br /> quickly accumulate significant amounts of chemical pollution through fuel spills and drips, and
<br /> automotive fluid leaks.
<br /> The madtom,waterdog, and pigtoe all have similar habitat requirements. They are all sensitive
<br /> aquatic species that require high water quality. They are all sensitive to sedimentation, chemical
<br /> pollution, nutrient loading and water temperature fluctuations. In its proposed rules to list these
<br /> species, the Service describes how new development causes existential threats to the surviving
<br /> populations of these species:
<br /> "Urbanization increases the amount of impervious surfaces. "Impervious surface" refers to all
<br /> hard surfaces like paved roads, parking lots, roofs, and even highly compacted soils like sports
<br /> fields. Impervious surfaces prevent the natural soaking of rainwater into the ground and slow
<br /> seepage into streams. Instead, the rainwater accumulates and flows rapidly into storm drains,
<br /> which drain as runoff to local streams. This degrades stream habitat in three ways: Water
<br /> quantity (high flow during storms), water quality (pollutants washing into streams), and
<br /> increased water temperatures due to the surfaces heating the water.
<br /> Concentrations of contaminants, including nitrogen, phosphorus, chloride, insecticides,
<br /> polycyclic aromatic hydrocarbons, and personal care products, increase with urban development
<br /> (Giddings et al. 2009, p. 2; Bringolf et al. 2010, p. 1,311). Water infrastructure development,
<br /> including water supply,reclamation, and wastewater treatment, results in several pollution point
<br /> discharges to streams."
<br /> 84 Fed. Reg. 23,649(May 22, 2019).
<br /> "Impervious surfaces associated with development negatively affect water quality when
<br /> pollutants that accumulate on impervious surfaces are washed directly into the streams during
<br /> storm events. Storm water runoff affects such water quality parameters as temperature, pH,
<br /> dissolved oxygen, and salinity, which in turn alter the water chemistry and could make habitat
<br /> unsuitable for the Atlantic pigtoe."
<br /> 83 Fed. Reg. 51,574(Oct. 11, 2018).
<br /> This sprawling development would contribute chemical pollution, sedimentation, and nutrient
<br /> loading to Hillsborough's water supply while degrading water quality in the proposed Eno River
<br /> critical habitat for all three of these imperiled local species. The proposed Efland Station would also
<br /> detrimentally raise the water temperature in this critical habitat by sending hot water directly into
<br /> Sevenmile Creek when Summer rains wash off the hot asphalt of this filling station's behemoth
<br /> parking lot.
<br /> Page 15
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