November 20, 2008 - TVA DEA Attachment "E"

TVA DEA ATTACHMENT "E" Categorical Exclusion Checklist

TCHA Comments

The following line items that should be changed from "No' to "Yes" in the CEC

PART & ITEM - TVA "Quoted" followed by the TCHA RESPONSE

Part 1, item #3 - "Involves non-routine mitigation to avoid adverse impacts ?"

This would involve non routine mitigation to avoid adverse impacts

to several other items



item # 6 –“Is one of many actions that will affect the same resources ?"

Would affect the same land resources if the designation of any

portion of Parcel 52 were reclassified to Industrial, as the TC

Recreation Department use of the remainder of has been refused

by Soccer Teams, and others, to locate recreation or park (kite

flying, ball games, etc.) adjacent, as a power sub station would

render recreation uses "impossible".



item #7 - "Involves more than minor amount of land ?"

By the approval of the 1.6 acre Sub Station on 17% of the
9.5 acres f currently designated as "Recreation" on Parcel 52,
the remaining 83% of the land would be rendered as "useless"
for recreation uses, as commented on by coaches of the Towns
County Youth Soccer Teams and other recreation users. -
These teams currently have more than 190 players enrolled.



item # 8 - "Potentially affect ecologically critical areas, federal, state, or local

park lands, national or state forests, wilderness areas, scenic areas

wildlife management areas, recreational areas, greenways or trails ?"

Scenic areas, recreational areas, and greenways (All three!!) would

be adversely affected.



item #13 - "Potentially affect drinking water supply ?"

The only intake for the Towns County Water Authority, and City of
Hiawassee is only 4/10 mile downstream, from Parcel 52. This could
be fouled by the BRMEMC proposed sub station landfill and
construction below the previously TVA enforced "no land fill no
construction below 1933 elevation" which is classified as
"full capacity" of the reservoir.



Part 3, item # 5 - "Discharge dredged or fill materials ?"
Due diligence has Not been exhibited by BRMEMC to date as to
their estimated $100,000 cost for this site, including improvements.
The BRMEMC project description stating only "0.2 acre feet"
(2.4 Inches !!) is an obvious mistake as is their estimate of
"21 cu. yds." of fill. So, the following data is estimated by laying the
proposed 1.6 acre site plan over the TVA topographic contour maps:

This data presents basis for concern about "Discharge. . .filled
materials". Using the BRMEMC layout showing approximately 1 acre
requiring fill to get "above the 1933 elevation" the "full capacity"
of the reservoir (required by TVA) would require an average acre
depth of 4 feet(compacted 20% to 3.2 feet) = 6518 cu. yds.
If hauled by large trucks of 17 cu.yd. capacity, this would total 384
truck loads at average cost of $250 each at present day cost per
truckload for total contracted fill cost of $95,860.
This large amount of fill should be contained by a Poured Concrete
Wall and drained in accord with TVA requirements (page 3),
that require Georgia Storm Water Permit. BRMEMC has costed
as significantly smaller amount of fill than this for Parcel 52.
By their own admission, their numbers are “best guesses” only.
The fill conclusions also raise considerable concern about discharge
from fill. Actual costs for site purchase, including site preparation,
could probably be several hundred thousand dollars more than the
$160,000 total, including property, stated by the BRMEMC in
their presentations and rudimentary cost figures for Parcel 52.
Other sites BRMEMC contend they have considered, do not provide
detail in accord with Due Diligence for public review either.
Given their preference for Parcel 52 and their large understatement
of the filling cost, one has to wonder about the accuracy of the site prep
estimates on the alternative sites and whether they may be artificially
high (see $600k for fill on Parcel 51).
Using the BRMEMC project description, and the above preliminary
Calculations for Parcel 52, a large overrun of the stated BRMEMC site
costs would probably be experienced by BRMEMC and should be
revisited by the utility to gain a complete estimate and review of
related costs.



Part 4, item #2 - "Increase the potential for accidents affecting the public?"
There would be great potential for adults and children chasing balls,
kites and other objects that would go into the substation and cause
the persons to climb the fence to retrieve the objects and be subject
to electrical injury and/or death.



item #3 - "Cause the displacement or relocation of businesses, residences,
cemeteries or farms”. The presence of the proposed sub station
will likely cause the closing of the adjacent Campground and Marina
business on the land owned by Mrs. Palmer (see attached affidavit).
This is based on remarks by the tenants who say they would not
continue to rent the campsites for their trailers, or use the covered
boat slips if the substation were to be built on Parcel 52.



item #8 - "Potentially interfere with recreational or educational uses ?"

It certainly would interfere with the current recreational classification,
As parents and coaches have said the remainder of Parcel 52 could not
and would not be used by the Recreation Department because of the
potential dangers involved.