Several prominent Environmental, Conservation, and Nature-oriented Organizations have expressed their concerns to the Developer and the Morgan County Planning Commission about possible negative environmental and health/safety impacts resulting from the development and operation of an RV campground of this size …at this location.  Further, these organizations have expressed their encouragement and support for our efforts in making our concerns known to these decision-makers as well.

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Stewards of the Potomac Highlands

www.PotomacHighlandStewards.org

March 9, 2023

Stewards Statement Regarding Planned KOA RV Campground
To Be Sited in Great Cacapon

To Whom it May Concern:

Stewards of the Potomac Highlands, a 501c4 nonprofit citizens group, works in West Virginia’s northeastern counties to protect the area’s heritage of small farms and forest land and support an environmentally and socially sustainable, locally controlled economy. We join the signers of a petition in Great Cacapon who have expressed concerns about a proposed KOA RV campground proposed by Aaron Bills on his 48 acre site on Route 9 at the junction of the Cacapon and Potomac Rivers.

While the construction of 173 oversized campsites would bring business to the area, it is likely to also bring environmental harms including sewage pollution to the river, marring of the popular viewshed at Prospect Peak, traffic that could overwhelm local roads, a population influx that could overwhelm Great Cacapon, and questions regarding trash disposal and effects of the project’s well-drilling on the local fresh water table. Also, we are concerned about long term environmental effects if the project should fail, and Mr. Bills’ failure to address this possibility.

We want to see a cost-benefit analysis and a thorough environmental evaluation of the KOA project. We ask Morgan County’s Planning Commission, WVDEP, and the county Health Department to publicly address, and submit a plan to mitigate, all the environmental issues before the project is approved.

Stewards of the Potomac Highlands,

Bonni McKeown, President

Stewards of the Potomac Highlands
PO Box 232
Maysville, WV 26833

PotomacHighlandStewards.org

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Potomac Riverkeepr Network
Friends of the Cacapon River

www.potomacriverkeepernetwork.org
www.cacaponriver.org

Position Statement Regarding Proposed KOA Campground in Great Cacapon, WV

April 25, 2023

The Mission of Potomac Riverkeeper Network is to protect the public’s right to clean water in the Potomac and Shenandoah Rivers and their Tributaries. We stop pollution to enhance the safety of our drinking water, protect healthy river habitats, and enhance public use and enjoyment. The mission of the Friends of Cacapon River is to preserve, protect, and promote the environmental health and scenic character of the Cacapon River and its watershed. The following statement is a joint position regarding the proposed KOA campground in Great Cacapon, WV.

The proposed KOA Campground project is located within the Upper Potomac and the Cacapon River therefore has been reviewed. There are several pollution issues that impact the Upper Potomac watershed from acid mine drainage to failing wastewater treatment plants. Sediment and nutrient pollution from land-based activities, such as farming and construction, are also significant issues that impact our rivers and streams. Climate change and increased weather events in severity and duration have exacerbated stormwater pollution from land activities. After careful review of the proposed KOA Campground, Potomac Riverkeeper Network and Friends of the Cacapon River take a precautionary approach to the project, meaning work should not start until satisfactory assurances are provided by the developer to address the following concerns with measures that can be independently verified.

Wastewater connection and Treatment: PRKN conducts permit reviews through a review of the EPA ECHO database system. The wastewater treatment plant in Great Cacapon has not violated it’s discharge permit for the last 6 quarters and remains in full compliance. According to the NPDES permit, the facility has enough capacity to accomodate the proposed KOA effluent volume. However, the current system has only encountered small volume flows into the facility with some increases due to seasonal residents or older sewer system with an aging infrastructure that may have cracks, allowing ground and surface water to flow into the sewer system during rain events. Caution must be taken to ensure the new larger volumes of effluent from the KOA will not overwhelm the existing waste treatment process.

The proposed routing of the new sewer line to the wastewater plant in Great Cacapon must cross the Cacapon River. The proposed use of horizontal directional drilling to route the sewer line under the Cacapon River does come with potential risks of sediment pollution from equipment use and in more severe cases, a rupture of the drilling mud directly into the river. We are requesting that the State and Developer take extreme caution to ensure as minimal as possible any pollution during the sewer line routing phase of the project.
We strongly encourage Scenic, LLC to minimize sediment impacts on the watershed during and after construction. We call for Scenic, LLC to protect the riparian area, within 100 feet of the stream bank. Scenic should exclude any campsites or support infrastructure in the riparian buffer and there should be no construction activity within 100 feet of the stream bank. We encourage Scenic to minimize mature tree removal and protect the existing plant community including herbs, woody and shrubs. In addition, we encourage Scenic to install additional native perennials, grasses, shrubs and tree plantings. We are encouraged that the Berkeley Springs KOA includes stormwater best management practices.

Stream Habitat Disturbances and Public Access: The mission of PRKN and FCR includes the protection of healthy habitats and enhancing the public use and enjoyment of the rivers and streams in the Potomac and Shenandoah Rivers. The current public access to the Cacapon River at the bridge on Cacapon Rd is within the property lines of the proposed KOA. We strongly encourage that the access to the river remains open to the public and that the KOA would also ensure proper maintenance of the access area.

We also understand that an increase in patrons enjoying the Cacapon River brings a certain potential for stream habitat disturbance. The Cacapon River is home to many important aquatic floral and fauna, including some endangered mussel species. We strongly encourage the KOA property managers to have a ”Leave No Trace” policy and signed commitment of campers during the registration process. This may help to reduce nuisance disturbances of the stream habitat.

Emergency Response to Pollution Releases: Great Cacapon and by extension the KOA is in an isolated location that does not have quick access to emergency services. There should be an Emergency Response Plan for Great Cacapon in case of an emergency. With the recent train derailments across the country, there is a growing concern that our towns and communities located along rail lines are more susceptible to severe emergency situations that could cost human lives and cause environmental harm. The CSX tracks accommodates a number of industrial products that may become dangerous to people and the environment if there was to be a derailment in or near Great Cacapon. The development of the KOA adds a layer of traffic concern that must be factored into an Emergency Response Plan. Increased traffic on Cacapon Road may become an impediment to emergency services in responding to an incident.

Brent Walls
Upper Potomac Riverkeeper
Williamsport, MD 21795
www.potomacriverkeepernetwork.org

Tim Reese
Friends of the Cacapon River
Capon Bridge, WV 26711
www.cacaponriver.org