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Sound Rivers is a 501(c)(3) environmental non-profit organization that serves the Neuse and Tar-Pamlico River basins, and seeks to protect, monitor, and enhance the waters of these basins through advocacy, research, restoration and education. Sound Rivers has a 42-year history of working to address water quality pollution and flooding issues in the region. Sound Rivers and our stakeholders submit these comments respectfully requesting that the Raleigh City Council deny the proposed Gorman Street Rezoning Z-35-23.

We request that Raleigh City Council exercise their authority to deny the rezoning of this 17 acre parcel from conservation management to residential uses because of concerns including topographical challenges, increasing flooding in an existing flood-prone area and potential impacts to the federally impaired Walnut Creek.

While we appreciate the applicant’s commitment to additional conservation and stormwater management conditions, we believe that the applicant must go further to prevent flooding and water quality impacts in this sensitive, flood prone part of the watershed.

Please consider our comments below regarding these concerns:

Despite added conditions, this proposal would likely increase flood risk, in an already flood-prone area. As is acknowledged in the application, the project area is within a FEMA-designated floodway and

floodplain area, with flood hazard soils. Additionally, the intersection of Walnut Creek and Gorman Road is listed on the City of Raleigh’s Frequent Flooding Map as a repeat flooding location, when during times of heavy rain, road flooding is anticipated.

Several tributaries that flow from this project site already exhibit significant erosion and downcutting from flashy stormwater runoff. These tributaries would be overburdened by additional runoff from increased impervious surfaces in this now forested area. In the context of climate change, we suggest that planning for the 25-year storm is not sufficient to prevent additional future flooding impacts in this location.

If the developer plans to avoid seeking out a citywide variance to construct in the 100-year floodplain, then they are forced to construct in the northern corner — a very steep portion of the property. This topographical challenge will likely necessitate blasting and grading of this parcel, which will further challenge the receiving waterways downgrade of this area. In addition to providing additional stormwater conditions, the applicant should provide additional conditions to mitigate sedimentation impacts from steep-slope development near these small feeder-streams to Walnut Creek.

This proposal would impact existing low-income communities.

Sound Rivers appreciates the desperate need for affordable housing in Raleigh, and supports the creation of more housing wherever feasible and environmentally responsible. However, we do not support the creation of more housing if it means worsening flood risk for existing and future under-served community members.

According to NC Department of Environmental Quality’s Community Mapping System, this area is considered an underserved community block, with 53.68% of the population classified as low-income. Therefore, this proposal raises environmental justice concerns by potentially worsening flood risk in a predominantly low-income, already flood prone area.

This development would impact an impaired and federally recognized watershed. Please consider the watershed context of this proposal. Walnut Creek is listed on the US EPA’s 303(d) list as federally impaired, due to a history of dumping, industrial pollutants and urban flooding. Today, Walnut Creek has received the great honor of becoming the first urban waterway in the state of North Carolina to receive the Urban Waters Federal Partnership designation, signifying a commitment to federal investment in water quality and flood prevention in this urban waterway. Federal and local partners are currently working hand in hand on good watershed works in the Walnut Creek watershed, including significant investments in green stormwater infrastructure projects, water quality sampling, and community engage efforts. Development of this currently forested area would undermine this important commitment to water quality and flood resiliency in the Walnut Creek watershed.

Given these considerations, we request that decision makers deny the 0 Gorman St. (Z-35-23) Rezoning Proposal, or otherwise defer it to the Council Growth and Natural Resources subcommittee to discuss further conditions that the applicant can provide to mitigate these enumerated impacts. Ideally, the City of Raleigh would look to satisfy the need for developing low-income housing by utilizing other available assets like existing parking lots, and re-developing rather than converting valuable greenspace.

Thank you for your time and consideration of this comment,

Samantha Krop

Neuse Riverkeeper, Sound Rivers