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HomeMy WebLinkAbout20070168 Ver 1_Public Notice Response_20080925/ MACTEC Engineering and Consulting J M A T E 1 Patton Avenue Asheville, North Carolina Phone: (828) 252-8130 Fax: (828) 251-9690 LETTER OF TRANSMITTAL o _ o t to g TO: NkS. Cyndi Karoly NC Division of Water Quality 2321 Crabtree Boulbard; SW4. Ralfigh, NC 27604 (919) 733-9721 WE TRANSMIT TO YOU: DATE: 09/23/2008 MACTEC PROJECT NO.: 6229-05-2914; Task 15 250 PROJECT NAME: Grandview Peaks SUBJECT: DWQ Alternative to Predictability Study HEREWITH ? UNDER SEPARATE COVER SUBJECT: ?DRAWINGS ?SPECIFICATIONS ?CALCULATIONS ®REPORT ?COST ESTIMATE ?AS NOTED ACTION: SENT BY: ?FOR YOUR INFORMATION ?MAIL ®FOR YOUR COMMENT OR APPROVAL ?CERTIFIED MAIL ?RETURNED FOR CORRECTION: RESUBMIT NEXPRESS FED ?APPROVED AS NOTED ?COURIER ?AS REQUESTED ?HAND DELIVERED ?FACSIMILE: inc transmittal COPIES DATE DESCRIPTION 09/23/08 Impoundments Watershed Modeling and Adaptive Management REMARKS: Please find attached Bse copj 20n-site, Impoundments Watershed Modeling and Adaptive Management Plan. Should you have any questions, please contact Robert Sain at (828)-252-8130 or Allen Conger (803)-798-1200 SAP ?' .. CC: Todd Black; Fall Creek Land Company Cyndi Karoly; DWQ; Raleigh Headquarters Kevin Barnett, DWQ, Asheville Field Office Amanda Jones, USACE, Asheville Regulatory Field By: _12 -- /_ < - Robert L. Sain Direct Phone: (828) 252-8130 CONFIDENTIALITY NOTICE: This message is intended only for the use of the individual or entity to which it is addressed, and may contain information that is privileged, confidential, and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone and return the original message to us at the above address via the U.S. Postal Service. Thank you. If transmission is not received in good order, please call Tracy Effler at (828) 252-8130 D--en15 Form Revised 10 18 02 ?JMACTEC engineering and constructing a better tomorrow September 23, 2008 Ms. Cyndi Karoly N.C. Division of Water Quality 401 Oversight/ Express Review Permitting Unit 1650 Mail Service Center Raleigh, North Carolina 27699 S?.P U n1?4 , :'. P,i c; J", 1' Subject: The Grandview Peaks Development On-site Impoundments Modeling and Adaptive Management Plan USACE Action ID: 2007-200-359 DWQ Project # 07-0168 McDowell County, North Carolina MACTEC Project No. 6229052914 Dear Ms. Karoly: MACTEC Engineering and Consulting, Inc. (MACTEC), on behalf of the applicant, the Fall Creek Land Company (FCLC), would like to address Division of Water Quality (DWQ)'s request for a watershed modeling plan; request made during a meeting at the DWQ, Raleigh office July 21, 2008 (see Attachment A). The purpose of this document is to present a scientifically valid watershed modeling plan, to accomplish the goal of preserving water quality. We would appreciate your timely review of this information and your written response regarding the acceptability of this modified procedure for the required analyses. cc: Todd Black, Fall Creek Land Company Amanda Jones, Asheville Regulatory Field Office, USACE Ion McMillan, Raleigh Headquarters, DWQ Kevin Barnett, Asheville Regional Office, DWQ MACTEC Engineering and Consulting, Inc. 1308 Patton Avenue 0 Asheville, NC 28806 • Phone: 828.252.8 130 • Fax: 828.251.9690 www.mactec.com Project Overview: The Fall Creek Land Company's (FCLC) "Grandview Peaks (GP)" development contains 54,392 linear feet of jurisdictional, perennial, and intermittent stream channels. The north-western portion of the property contains two networks of unnamed tributary streams that drain to Hopper's Creek. The FCLC plans to impound these unnamed, tributary stream systems to create small reservoir lakes (27.1 acre and a 6.8 acre). Both lakes are down gradient from existing development activity and are the most feasible location on the property-having the right combination of drainage area, perennial stream flow, constricted valleys (see Figure 1). Both proposed impoundment(s) will be located in the upper Catawba River Basin (HUC 03050101; sub basin 03-08-30) within the Northern Inner Piedmont Ecoregion. Background Information: A list of project milestones has been provided in Appendix A. The DWQ recently (March 2008) came out with an analytical monitoring protocol to predict how water quality will affect future impoundment(s) (March 2008, Predictability Study Protocol for Sampling Reference Impoundment(s) NCDWQ, 2008). These guidelines currently state that applicants wishing to build new impoundment(s) conduct rigorous monitoring of two "similar, existing" lakes as reference for what to expect. The Fall Creek Land Company (FCLC) provided an alternative to the DWQ's guidelines on July 8, 2008; FCLC proposing a stand-a-lone procedure for predicting water quality, on-site. The GP alternative procedure uses watershed loading analyses consistent with the currently accepted and recommended DWQ lakes modeling procedures. The GP alternative procedure will ensure that appropriate BMPs are in place to establish and maintain impoundment(s) water quality. Purpose: During a meeting held on July 21, 2008 to discuss the project, MACTEC provided a modified monitoring plan, and the DWQ requested to see a draft of the Fall Creek Land Company's, proposed watershed modeling and adaptive management plan for the proposed reservoirs. The plans initial step required on-site assessment of existing water quality prior to development of the two proposed lakes. Pre-development existing water quality, can be used to set baseline parameters which the Fall Creek Land Company (FCLC) may use to set target threshold indicators for water quality for after the lakes have been created. The Draft Grandview Peaks Lakes watershed modeling and adaptive management plan is outlined as follows. Grandview Lakes Monitoring Plan September 23. 2008 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 1) 7 283 -Al Lake #3 Down stream ?.. Statio Sam li L k #2 D t p ng n . I GP-L3-D1 a e own s ream Sampling Station GP-L2-D1 #2 Up stream ling Station 1 $° [ -.` ., ;?' SAO GP-L 2-U1 - if C reak ,.: Mt 1 t y j i I { a ke #3 Up stream -`? `- La Sampling Station r - =1.. - - ,, i h GP-L3-U1 ,--?; ? i ' ! n Lake #2 Up stream Sampling Station Lake #2 Up stream Sam lin Station Y GP-L2-U2 •+ GP-L p g - 2-U3 t ? r , f ? QwnCe, 1\. ?,1 4 1'\ x191 - I f L__ n n at" l Lgakadoo Mcu LEGEND Streams 0 Property Boundary 0.25 0.5 0.75 1Miles Proposed Lake Boundaries 0 Feet r 1,250 2.500 3.750 5.000 Source: USDA DRG Mosaic for McDowell Co. . North Carolina 2007 GRANDVIEW PEAKS DEVELOPMENT SAMPLING LOCATIONS FOR PROPOSED LAKES #2 AND #3 MACTE C MCDOWELL COUNTY, NORTH CAROLINA REPAREDSJM DATE r 09/12/08 CHECKED RLS BY DATE 09/12108 JOB NUMBER 6229 -05-2914 FIGURE 1 I. Watershed Modeling A detailed watershed model will be developed to quantify loading contributions from both upstream portions of the watershed as well as changes to water quality loading parameters that are anticipated (in the absence of appropriate BMPS) with the development of low-density residential housing on site. Estimates of annual nutrient contributions entering via runoff from the residential community will be determined by identifying sub-basin drainage areas within the watershed. Watershed sub-basin delineation will be performed by incorporating aerial photographs of the site, topographic contours, and proposed conveyance structures within the community into a GIS platform for analysis. Calculation of annual runoff volumes and associated loading from the identified sub-basins will incorporate the following information into the watershed model: A. Precipitation Precipitation data will be collected from several local rain gauge stations near the proposed development. Multiple years of daily rainfall data, up to a maximum of 10 years, will be used in the model to most accurately reflect weather variations from drought, normal, and significant storm event rainfall periods. B. Watershed Characteristics Determination of surface water runoff during an individual rain event requires a known amount of precipitation falling on the project site as well as generated runoff curve numbers (CN). To determine the CN for the project area, land use type and hydrologic soil group values will be defined using Geographic Information Systems (GIS). Land use within the project area will incorporate the proposed residential development and newly constructed reservoirs to reflect future loading characteristics following the completion of construction. Interconnected Pond Routing Stormwater (ICPR) or similar modeling platform will be used to incorporate existing and proposed conveyance systems within the watershed. Using the predetermined curve numbers and regional precipitation data as inputs to the ICPR model, annual runoff volumes will be calculated for each sub-basin area within the watershed. Results of the Grandview Lakes Monitoring Plan September 23, 2008 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 3 ICPR model will provide accurate estimates of annual sub-basin runoff volumes based on changing land use and conveyance systems anticipated with the proposed development. Runoff volumes calculated within the watershed model will be used to estimate the annual nutrient load entering the proposed reservoirs via the project site. Nutrient loads are estimated by multiplying the annual runoff volume by the event mean concentration (EMC). EMCs are established for specific parameters of interest (TSS, TN and TP for this analysis) and vary by land use. Proposed BMPs developed during construction may also be incorporated into the annual loading estimates by identifying the portion of stormwater runoff treated through a given BMP. Characterization of existing water quality in several streams within the watershed was completed to provide an assessment of baseline water quality conditions and upstream loading contributions. Water quality monitoring was performed at six sampling stations in flowing portions of upstream tributaries. Based on field observations, one of the possible locations entering proposed impoundment(s) was found to be an intermittent stream, and did not have adequate flow for sampling. Five stations were sampled on August 6, 2008 within "the hottest period of the year" between the August l st and August 30th. The five stations included sample locations in two sub- watersheds; the proposed Lake#2 impoundment(s) and the proposed Lake#3 impoundment(s) (see Figure 1). • Station GP-L2-U1: Downstream of confluence at the dendriditic tributary split. • Station GP-L2-U2: Located 105 stream meters up stream of gravel road (wet crossing). • Station GP-L2-U3: Located approx 80 meters up stream of culvert at gravel road. • Station GP-L2-D1: Located in run section, just upstream of large bedrock pool. 30 meters up stream of waterfall section. • Station GP-L3-U1: Located 30 meters north of gravel road. • Station GP-L3-D1: Located 20 meters downstream of flag line for dam. Water sampling protocols adhered to the requirements described in the Predictability Study Protocol for Sampling Reference Impoundment(s) (NCDWQ, 2008). Water quality parameters measured included water temperature, dissolved oxygen saturation, pH, turbidity, nutrients (total phosphorus, total Kjeldahl nitrogen, ammonia [NH3], nitrate + nitrite [NO2+NO31), chlorophyll-a (corrected for pheophytin), and fecal coliform. Grandview Lakes Monitoring Plan September 23, 2008 McDowell Lakes Development Site, McDowell County- North Carolina MACTEC Project No. 6229052914 4 Water Quality results for August 6, 2008 monitoring data provided in Table 1. Table 1: Draft On-site results; August 6, 2008. Grandview Peaks / MACTEC Water Quality sampling (August 6, 2008) prelim results. On-Site Meter n.,.i,hi..i i nk Proposed Lake #2 Proposed Lake #3 Stream Monitoring Parameters GP-L2-U7 GP-L2-U2 GP-L2-U3 GP-L2-01 GP-L3-U1 GP4L3-D1 8.09 8.5 7.95 7.9 n/a 8.04 condudw mS 2.2 0.39 0.036 0.05 n/a 0.03 Dissolmd Oxygen L 10.7 9.8 10.6 10.2 n/a 10.24 Temperature (degrees C 21.6 21.4 21.4 21.1 n/a 22.2 Salinity 0.00 0.00 0.00 0.00 n/a 0.00 Fecal Coliforms CFU/ 100mL SM 9222D 112 12 152 304 n/a 104 Turbidity (NTL? EPA 180.1 16 2.6 4.2 13 Nei 5.7 Total Suspended Solid L SM 2540D 34 40.3 8 7.3 n/a 19.3 Ammonia m L EPA 350.1 nd nd nd nd n/a nd Nitrogen N02 plus N03 m L EPA 353.2 0.02 0.09 0.08 0.17 Na 0.04 TKN m L EPA 351.2 0.54 0.36 0.57 0.55 n/a 0.41 Total Nitrogen (mg/L) EPA 353.2 0.55 0.45 0.66 0.73 Na 0.45 Total Phosphorus (mg/L) (EPA 365.1) 0.028 0.015 0.006 0.016 n/a 0.012 Estimated Gradient (%) 1.8 3 to 6.8 .7 n/a 0.3 Wetted Width of stream ft 1.9 3.5 .5 n/a 2.5 Max Depth of stream ft 0.9 0.3 65 n/a 0.14 Location GPS see ma see ma 2seemap ma see ma see ma Weatherdescri lion sunn sunny nny sunny sunny Air Tem rature de rees C) 1 32 32.6 - 2 33 33.5 Comments ink fla in ink flagging I in no water ink fla in Created By: RLS, Sept, 2008 Checked By: ABS, Sept, 2008 This recent surface water monitoring data will be used to establish baseline water quality conditions within local streams and upstream tributaries, and will serve as a target for future stream water quality following construction. Existing water quality measurements recorded in the streams will be incorporated into the watershed model to provide a benchmark for current water quality conditions, which may then be compared to subsequent stream water quality following residential construction. Baseline water quality data provided in Table 1 will be used in the watershed model to develop loading estimates from contributing (upstream) portions of the watersheds. Results of the loading estimates from the surrounding watershed will then be combined with the measured nitrogen, phosphorus, and TSS load from these tributaries to determine a total annual load for the impoundment(s). Estimates of the annual nutrient load within each reservoir may then be used to determine appropriate Best Management Practices (BMPs) to eliminate the incremental loading difference associated with the construction of the residential community. Grandview Lakes Monitoring Plan September 23, 2008 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 5 Best Management Practices (BMPs) will be selected to account for loading entering through additional residential development, as determined in the watershed model. If the results of the watershed model determine that additional BMPs are needed, BMP selection and design criteria will be guided using the North Carolina Division of Water Quality Stormwater Best Management Practices Manual (NCDWQ, 2007). A number of BMP design options may be chosen to capture excess runoff prior to entering local streams or the proposed impoundment(s), including, but not limited to: a. Dry retention basins; b. Wet detention basins; c. Stormwater wetlands; d. Bio-retention; e. Infiltration devices; and £ Grassed swales (etc.) Emphasis will be given to BMPs that are considered Low Impact Development (LID) and sustainable for preservation of water quality and quantity. A number of LID alternatives for stormwater management are available, including, but not limited to: a. Minimizing impervious area; b. Rainwater harvesting; c. Incorporating permeable surfaces, d. Depression storage; and e. Soil filtration To ensure that portions of each tributary below the impoundments are not negatively impacted by the construction of the proposed impoundment(s), out flowing water quality may also be preserved through best management practices within each impoundment(s). These practices are likely to focus on temperature, dissolved oxygen and related constituents, and may include conditions of management of water withdrawal from the impoundment(s), among other factors. BMP design and implementation will utilize watershed loading estimates, upstream and downstream surface water monitoring, and examples from similar impoundment(s) within the regional area as guidance for managing water quality exiting the impoundment(s). BMPs within Grandview Lakes Monitoring Plan September 23, 2008 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 6 the impoundment(s) will be designed and implemented, if necessary, to ensure that water quality flowing downstream of the impoundment(s) is similar to the water quality of upstream tributaries. II. Adaptive Management Plan The purpose of an adaptive management plan is to provide for flexible management of the proposed reservoirs, based upon a feedback loop so that management strategies are adjusted to address changing field conditions, to maintain downstream water quality. Watershed BMPs are anticipated to be sufficient to maintain nutrient loading at current levels. Impoundment of the water will, however, potentially cause changes in surficial water temperature during summer months. Primary water quality indicator of the physical affects of impoundment may be captured by measuring temperature and dissolved oxygen at the surface and at depth during summer. It is anticipated that during seasons where water temperatures in the stream are similar to surficial impoundment temperatures (spring, winter, and fall), surficial water may be gravity fed over a spillway or other conveyance, to the stream. When the need arises (e.g. when the temperature and/or DO differential from upstream and impoundment require action), water for downstream replenishment will be pulled from cooler, deeper waters of the impoundment, and oxygenated, if necessary. These parameters (temperature and DO) provide a quick and reliable method of assessing water quality within the reservoir. Reports of impoundment(s) water quality may be provided to the NC DWQ 401 Oversight Unit as requested. This adaptive management plan focuses on the preservation of water quality both within the constructed impoundment(s) and in downstream creeks. This management follows existing recommendations from USEPA and the North American Lake Management Society. Existing water quality conditions as sampled prior to construction may be used as baseline standards for the preservation of water quality within downstream creeks. Select BMPs as described in Section I also are anticipated to be utilized to ensure preservation of baseline and state water quality standards. Grandview Lakes Monitoring Plan September 23, 2008 McDowell Lakes Development Site. McDowell County, North Carolina MACTEC Proiect No. 6229052914 7 References: EPA, 2000. Ambient Water Quality Criteria Recommendations. Lakes and reservoirs in Nutrient Ecoregion IX. United States Environmental Protection Agency. EPA 822-13-00-011. December 2000 NC DENR - Division of Water Quality "Redbook" Surface Waters and Wetlands Standards NC Administrative Code 15A NCAC 02B .0 100, .0200 & .0300 Amended Effective: May 1, 2007; Raleigh, North Carolina: http://ii2o.enr.state.nc.us/adniin/rules/doeuments/redbook full with cover.pdt' Closing The Fall Creek Land Company appreciates your timely review of our response to your request to see a Watershed Modeling and Adaptive Management Plan for the Grandview Peaks Development. Sincerely, MACTEC ENGINEERING AND CONSULTING, INC. /2-/ S -7a 'V04 Robert L. Sain, CFM for GU-A AdIkAnn B. Shortelle, PHD Project Scientist with permission Limnologist/ Chief Scientist Grandview Lakes Monitoring Plan September 23, 2008 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 8 Attachment A: Recent Project Milestones: January 16, 2007: The FCLC submitted a combined "Individual 404/401 Permit application" to the USACE and DWQ. September 25, 2007: The USACE, DWQ, commenting agencies, and public came back with public notice comments to be addressed. FCLC's "Response to Pubic Notice Comments" was submitted to the USACE and NC DWQ. September 2007 through January 2008: consistent efforts were made by the Fall Creek Land Company to contact regulators while the waiting for responses. January 4, 2008: The USACE responded, informally with an email dated. January 10, 2008: A site meeting occurred with Ms. Amanda Jones, Asheville field office of the USACE. January 23, 2008: The DWQ responded formally to the "Response to Public Notice Comments" with a letter stating that the application was "incomplete" pending analytical monitoring (Attachment A). February 6, 2008: a follow-up office meeting took place with the USACE the USACE informally requested additional information. This additional information was submitted to the USACE, Asheville Field Office on June 24, 2008. February 2008 through June 2008: various correspondences took place between the Fall Creek Land Company and regulators while drafting additional response documents to address concerns and new protocols. June 23, 2008: a brief follow-up meeting took place with the USACE to discuss the draft Additional Comments Response document. June 24, 2008: The FCLC Draft - USACE Additional Comments Response document was submitted to the USACE and copied to the DWQ. July 8, 2008: the FCLC, On-Site Impoundment(s)s Sampling Protocol document was submitted to the DWQ and copied to the USACE July 21 2008: A meeting took place in Raleigh at the DWQ headquarters to discuss the FCLC sampling protocol document and the project status. Action to the FCLC to capture, on-site, August water quality and to carryon with the FCLC proposed sampling protocol. August 6, 2008: Per the DWQ meeting, the FCLC conducted in-situ and analytical on-site sampling at five locations adjacent to the proposed lakes. August 29, 2008: On-Site Grandview Peaks, analytical sampling data results back from labs. Grandview Lakes Monitoring Plan September 23, 2008 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 2 1 4VMACTE_4'C ' ?-- engineering and constructing a better tomorrow ' September 25, 2007 District Engineer U.S. Army Corps of Engineers Asheville Regulatory Office 151 Patton Avenue, Room 208 ' Asheville, North Carolina 28801-5006 Attn: Amanda Jones, Project Manager, Asheville Regulatory Office ' Subject: DRAFT - Response to Public Notice Comments USACE Action ID: 2007-200-359 ' DWQ Project # 07-0168 McDowell Lakes Development McDowell County, North Carolina ' MACTEC Project No. 6229052914 Dear Ms. Jones: ' MACTEC Engineering and Consulting, Inc. (MACTEC), on behalf of the applicant Mr. Todd Black of Fall Creek Land Company (FCLC), would like to address recent public notice comments and concerns on the proposed construction of three lakes at the McDowell Lakes in t McDowell County, North Carolina. The above-referenced public notice was dated February 14, 2007. Individual comments to the public notice were received by the U.S. Army Corps of Engineers (USACE) between February 17, 2007 and March 15, 2007. Comments were provided ' by the N.C. Department of Environment and Natural Resources (NCDENR) Division of Water Quality (DWQ), the United States Fish and Wildlife Service (USFWS), the N.C. Wildlife Resource Commission (WRC), and the N.C. Natural Heritage Program (NHP). Since receiving ' the public notice comments, MACTEC has discussed the project with staff from various federal and state agencies to facilitate the review of the joint federal and state permit application. These discussions have resulted in some refinements to project components, as presented below. U.S. Army Corps of Engineers ' Comment No. 1: In the April 27, 2007, comment letter, the USACE requests that FCLC, with regards to the purpose and need of fire suppression, provide information that explains how existing lot owners will have access to water supplies for fire suppression in the event that this ' permit request is denied. Response: Lot owners will only have access to water from groundwater wells and other minor ' fire suppression methods or materials including: personal fire extinguishers, clearing and control of fire-prone vegetation methods, and small stream channels to access water if and when water is present in the channels. According to Mr. Jim Buckner, Fire Marshall of the Dysartsville ' Volunteer Fire Department, the fire department has one pump truck with a 10,000 gallon capacity to service the local area. At this time, no public water utilities are available to the McDowell Lakes development. MACTEC Engineering and Consulting, Inc. ' 1308 Patton Avenue • Asheville, NC 28806 • Phone: 828.252.8 130 • Fax: 828.25 1.9690 www.mactec.com ' Response to Public Notice Comments (P/NSAM--2007-200-359) September 25, 2007 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 The need for fire suppression was put to test recently as a forest fire burned on the 1VIcDowell Lakes development property nearly involving two homes prior to being brought under control. ' This event initiated a response from both the local volunteer fire department, from near Dysartsville, and the N.C. Division of Forest Resources (NCDFR) to aid in the extinguishing of this fire. As indicated by a letter (Exhibit A) supporting the permit applicant's effort to construct lake(s) at the McDowell Lakes development, Mr. John Reese, McDowell County Forest Ranger ' with the NCDFR, details current fire suppression resources and points out that the closest "water point" for firefighting vehicles responding to The project site is approximately five miles from the entrance to the development. Mr. Reese also details why on-site streams do not offer a ' reliable source of water for fire suppression. Lakes or ponds that rely on surface run-off water supply for recharge can potentially dry up during periods of drought. These surface waters are considered un-reliable sources of water by the NCDFR. ' Comment No. 2: In the April 27, 2007, comment letter, the USACE requests a detailed economic cost-benefit analysis that addresses the purpose and need of the project and includes the quantity and location of lake-front and lake view lots and the percentage of lots that have already been sold. In addition, the USACE requests that this analysis include the comparative market analyses that were used to estimate the revenue increases associated with the lake front view properties. ' Economic Cost Benefit Analysis enclosed (see Exhibit B). ' Response: A study conducted by the National Association of Home Builders (NAHB )indicates that "whether a beach, pond, or stream, the proximity to water raises the value of a home by up to 28 percent." A 1991 American housing survey conducted by the Department of Housing and ' Urban Development and the Department of Commerce also concurs that "when all else is equal, the price of a home located within 300 feet from a body of water increases by up to 27.8 percent" (NAHB, 1993). ' As a consequence, the proposed lakes at the project site will provide runoff holding capacity and have a permanent pool to facilitate fire suppression. Storm flows can be held in the pond temporarily and then released to maintain healthy downstream habitats, although FCLC does not ' propose to inhibit flow to the downstream habitat. The proposed lakes will allow sediment and other pollutants to settle out of the water. As pointed out in the discussion of alternatives analysis in the USACE Individual Permit application (IPA), dated January 17, 2007, the ' construction of these two lakes will occur in the headwater portions of the streams, which are degraded due to historic and recent silviculture practices. Impoundment of these headwater areas in the lakes will reduce further degradation of the downstream aquatic habitat. ' Comment No. 3: In a letter dated April 27, 2007, US ACE commented that the mitigation should be provided in accordance with the Interagency Stream Mitigation Guidelines. The USACE also ' requested that information be provided to categorize the type of stream channel impact (fill v. flooded) for each impoundment and the corresponding stream channel quality designation for each impact type. ' Response: The proposed mitigation has been planned in accordance wit the Stream Mitigation Guidelines. The estimated stream channel impacts are as follows: Interagency t 1 A2 1 1 1 1 1 1 1 1 1 1 1 1 1 Response to Public Notice Comments (P/NSAM-2007-200-359) McDowell Lakes Development Site, McDowell County, North Carolina MA CTEC Project No. 6229052914 Septe•mher 25, 2007 Table 1. Proposed Lake Impacts to Streams at the McDowell Lakes Development, McDowell County MAP ID Feature' Stream Quality Type of Impact Proposed Impact Lake ID ST-A P Good Flooding 769 Lake 2 " ST-A P Poor Flooding 625 Lake 2 Dam •ST-A P Poor Construction 200 Lake 2 ST-A P Poor Dam Outlet 70 Lake 2 ST-B P Good Flooding 109 Lake 2 ST-C P Fair Flooding 420 Lake 2 ST-C P Good Flooding 419 Lake 2 St-C P Excellent Flooding 100 Lake 2 ST-D P Fair Flooding 166 Lake 2 ST-E P Good Flooding 1125 Lake 2 ST-E P Fair Flooding 402 Lake 2 ST-E (2) P Good/Fair Flooding 182 Lake 2 ST-F P Good Flooding 90 Lake 2 ST-F P Poor Flooding 40 Lake 2 ST-H P Good Flooding 87 Lake 2 ST-1 P Fair Flooding 27 Lake 2 ST-J P Poor Flooding 75 Lake 2 IK P Fair Flooding 500 Lake 3 1K P Good Flooding 1315 Lake 3 Dam IK P Good Construction 175 Lake 3 1K P Good Dam Outlet 70 Lake 3 Total Linear Feet of New Lot and Road Impact 0 Sub-total Linear Feet of Fill Lake 2 270 Sub-total Linear Feet of Flooding Impact Lake 2 4636 Sub-total Linear Feet of Fill Lake 3 245 Sub-total Linear Feet of Flooding Impact Lake 3 1815 Total Linear Feet of Fill 515 Total Linear Feet of Flooding Impact 6451 Total Linear Feet of Proposed Lake Impacts (revised May 2007) 6966 P = Perennial In response to agency comments, the applicant has continued to avoid and minimize anticipated project impacts by removal of the previously proposed Lake 1 impoundment from the application. This site plan change has eliminated 300 If of proposed impacts to Excellent quality A-3 ' Response to Public Notice Comments (P/N SAM-2007-200-359) September 25, 2007 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 streams, 511 If of proposed impacts to Fair quality streams, and 246 if of proposed impacts to Poor quality streams (a total impact reduction of approximately 1,057 If). ' In accordance with the Interagency Stream Mitigation Guidelines and comments provided by the agencies during the on-site meeting of May 08, 2007 and from comments provided by the USACE, NCDENR DWQ, USFWS, WRC, and the U.S. Environmental Protection Agency ' (EPA). Since receiving the public notice comments, MACTEC has discussed the project with staff from various federal and state agencies to facilitate the review of the joint federal and state permit application. These discussions have resulted in some refinements to the mitigation plan, ' as presented below. Table 2 - Mitigation Credits for Proposed Impacts to Streams (Perennial). ' Channel Proposed Unavoidable Compensatory Basic Compensatmy Quality/Condition Stream. Impacts Mitigation Ratio Mitigation ' Re uirements Poor 740 1:1 740 Fair 1,515 1.5:1 2.273 Good 4,611 2:1 ' Excellent 100 3::l 300 * *300 Total Mitigation 12 535 Proposed * , ' Credits purchased from the NCEEP In-Lieu Fee Program. ' For impacts associated with dam construction, FCLC proposes a 1:1 ratio for impacts to 375 Lf of stream channel. FCLC proposes mitigation for proposed fill impacts of on-site stream channels by making payment to the NC EEP in the amount necessary to restore 3 75 'feet of stream channel in the Catawba River basin. The payment into NCEEP is proposed to ' compensate for impacts associated with dam construction to 3 75 linear feet of stream channel at a 3:1 ratio. Additionally, mitigation for the flooding of 6,412 linear feet of stream is proposed by preserving approximately 12,535 linear feet of stream channel with an approximately 120-foot wide riparian buffer (approximately 34 acres). The FCLC is willing to provide a protective mechanism to protect the additional 47,605 If of undisturbed streams within the subject property that are not being considered or proposed for mitigation, if the USACE is willing to provide ' some amount of additional mitigation credit to the project mitigation credit balance for this measure. ' If the USACE agrees, approximately 47,605 linear feet of stream channel will remain undisturbed with a 120-foot riparian buffer (approximately 131- acres). The applicant is proposing to preserve these additional areas in perpetuity using a deed restriction or other ' approved preservation mechanism. Wetland mitigation will be undertaken by purchasing 1.2 acres of wetland restoration from the t NCEEP In-Lieu Fee Program. H A-4 ' Response to Public Notice Comments (P/N SAM-2007-200-359) September 25, 2007 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 ' North Carolina Division of Water Quality (DWQ) In the DWQ letter dated February 16, 2007, various comments were presented, ranging from ' general comments to specific recommendations for the proposed project. The majority of the items of interest were initially identified during an inter-agency onsite meeting on May 8, 2007. The attendees included representatives from the Environmental Protection Agency (EPA), the ' WRC, the USACE, the USFWS, and MACTEC. For simplicity, each item of interest is individually addressed below. ' Comment No. 1: In the February 16, 2007 comment letter, the DWQ stated that the Project Purpose lacks a need. Response: A growth in residential development in the target market area of western North Carolina, which includes McDowell County, has resulted in a need for construction of single- family housing. Residential developments which provide lake amenities are presumed to meet th d e nee of the sector of potential home buyers which prefers this amenity among their basic requirements for purchase of a home. For other home buyers, the addition of lakes to a residential development may not be as important; however, it is presumed that few potential b ld di i ' uyers wou sm ss this amenity. To meet the need for construction of single-family housing in McDowell County, the permit applicant proposes to construct the McDowell Lakes project. As an integral component of the proposed subdivision, the applicant desires to construct two ' , approximate 25-acre and 9-acre lakes. The lakes will provide waterfront and lake-view residential lots, a community lodge facility, lake-side pavilion, and green space areas which are included in the conceptual plan of the development. An additional value of the lakes includes fire suppression water storage. The inclusion of the lakes to the development is presumed to meet a need for fire suppression water storage. See response provided under the USACE response item labeled "Comment No. 3". See also attached Exhibit A. ' Comme t N 2 Th n o. : e DWQ asks why a discussion of a fire suppression water supply was necessary and stated that "if impoundments are essential, then how is it possible to begin ' development and sell homes with the proposed amenity. Response: A lack of public water access from McDowell County water services currently exists for the proposed project area. A need for a dependable water source for fire suppression is ' perceived by most home buyers as necessary, or important, for any residential development. As stated in the previous response, the inclusion of the two lakes to the proposed development should meet the need for fire suppression water storage. The proposed McDowell Lakes project ' can not be completed if a dependable water source for fire suppression is not available. ' In order to address the second portion of the comment from DWQ concerning the pre-selling of lots at the Project site will require an explanation of real-estate development in that an unlimited supply of capital funds is not a realistic assumption to make. The FCLC is pre-selling lots at Project site in order to pay the development mortgage :loan. Because of the risk involved with ' such loans, the normal loan-to-value ratio is in the range of 60-66% of the total retail prices of the lots. The development loan provided sufficient funds to pav for the site acquisition and the development costs. The term of the loan is considered a short-term loan, one to three years. ' depending on the absorption forecast of lot sales. Because of the short term of the development loan, the interest rate is fixed. The loan is being repaid as a percentage of each lot sale, for example 50% to 75% of each lot sale would be deducted at each lot closing to repay the ' development loan as the lots are sold. The mortgage lender requires that the development loan A-5 ' Response to Public Notice Comments (P/NSAM-2007-200-359) September 25, 2007 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 be repaid faster or more proportionally than 100% of the lot sales. For example, the L ender may want 100% payback within 75% or 80% of the lot sales. This would, of course, require that the ' developer receive most of his/her profit during the later stages of lot sales. In this case, the return on investment is projected to come from sales associated with lots in later development phases including the lake lots. ' Comment No. 3: Application information 2.1 states that "the local municipal fire department {has stated} that it is advantageous to have a distance of less than or equal to three miles between hydrants." The DWQ responds that a review of the U:S. Geological Survey (USGS) topographic ' map for the area indicates that there is a significant sized impoundment within three rniles of the McDowell Lakes development. Response: Private or public access to a lake does not provide, in most instances, adequate dry access points for the collection of water or the availability of a dry hydrant. Based on a letter from the NCDFR, dated June 1, 2007, (Exhibit A) the only water resource available is i l f approx mate y ive miles away. Comment No. 4: The DWQ points out that the determination of an optional irrigation s st ' y em does not constitute a need. Response: The FCLC presumes that an optional irrigation system, via the proposed 25-acre lake, is a reasonable irrigation source to meet the need for watering of the lawn area around the subdivision clubhouse. An additional opportunity exists for the lot owners along the 25-acre lake to pump water from the lake to irrigate their lawns. ' Co t N 5 mmen o. : The DWQ points out that both Lake Lure and Lake James are withi a n n o e- half hour drive from the McDowell Lakes development offering boating access, fishing and ' , swimming. Response: Lake Lure and Lake James are within a 50-minute and 45-minute drive, respectively ' , from the McDowell Lakes development and do offer boating access, fishing, and swimmin g opportunities. However, driving times that approach one hour are too long for some people to undertake to access recreational waterbodies, especially if there are closer recreational waterbodies that are available that require less cost, time, and energy to get to. The FCLC ' understands that water-based recreational opportunities are important and close access to waterbodies is an important consideration of many recreational users. Potential buyers look for communities that offer on-site recreation which includes lake, ponds, walking and bike trails and , open space. If these communities are available, as offering on-site amenities such as maintained manmade lakes, then a select group of home buyers will purchase a vacant lot or ho i use n one of these communities ' . Comment No. 6: Application Information 23 ).1 states that fertilization may be necessary to support the planned fishery. You must provide details as to how Surface Water Quality ' Standards will not be violated. Additionally, you must provide compelling data as to the need for maximizing any proposed fishery. Response: The WRC will be consulted for recommendations prior to any future proposed fertilization or other fishery improvement measures. The applicant recognizes the potential surface water quality impacts of nutrient enrichment, and will work with the WRC to develop a management plan. for any constructed ponds/lakes on-site. If the WRC does not recommend A-6 ' Response to Public Notice Comments (P/N SAM-2007-200-359) September 25, 2007 McDowell Lakes Development Site. McDowell County, North Carolina MACTEC Project No. 6229052914 ' fertilization, then this will be excluded from the management plan. Previous information regarding maximization of proposed fishery resources was prompted by a general desire to ' provide high-quality aquatic habitat for game fish species. Comment No. 7: Application Information 2.3.1 states that "the demand for recreational fishing will be high for the Grandview Peaks development based upon the above calculations." (The above calculations are related to maximizing the fishery for production.) As maximizing the fishery does not equal a fishing demand, you must provide a compelling discussion as to how fishing demand was determined and why other facilities in the area will not provide fro this need, Response: Fishing demand is the effort, usually measured in time and number of individuals fishing, invested in the activity of fishing. Typically the amount of time spent fishing is ' proportionally related to the catch. In the application we used fish consumption as an approximation of fishing demand. Several stated assumptions were used to provide a realistic estimate for the given population. Assumption 1 is that 10% to 30% of the adult population will ' be recreational fishers; assumption 2 that most of the fish consumption will result from catch at local lakes, and assumption 3 that an average meal size is eight ounces, and assumption 4 that one individual would eat 38 meals of freshwater fish per year. Based on these assumptions, ' annual consumption for the communities is estimated to be 13,680 lbs of live fish/year (a proxy for fishing demand). Although assumptions are debatable, they support a potential for a significant fishing demand from this population. Based on the Pond Management Guide, it is estimated that productivity of the two lakes would not meet the estimated fishing demand. Fishing is not an activity driven only by consumption needs. Many fishermen find the activity peaceful and rewarding and often do not eat their catch but return it. Catch and release is becoming a popular trend among fishers which allows them to enjoy the activity while not removing the resource. Fishing is an activity that is enjoyed more often if it is convenient and ' productive for the sportsman (Bilgic and Florkowski, 2007). Traveling 50 minutes to Lake Lure or 45 minutes to Lake James is obviously not an absolute deterrent to an avid fisher. However, it . does present somewhat of a hurdle and would mean that residents who would like to enjoy a morning or afternoon on the lake will choose not to because of the inconvenience. Therefore this project will allow more individuals to enjoy fishing or other forms of water recreation more often. ' Comment No. 8: The DWQ requested that a survey be performed to provide accurate data with respect to Aquatic Biota in order to determine potential impacts. Response: A study of the Aquatic Biota was performed and is attached as Exhibit C. Using QUAL 4 sampling methods taxa abundance and diversity was found to be relatively good within all stream reaches sampled. According to the survey, the Order Epherneroptera exhibited the highest abundance within all stream channels sampled, with Plecoptera and Trichoptera generally second and third. Other Orders noted include Odonata, Diptera, ' Gastropoda, Coleoptera, Caudotal, Oligocheatal, Crustacea, Megaloptera, and Caudata. These Orders generally did not exhibit high relative abundance, with the exception of Odonata in channel segment K. All stream segments sampled exhibited high relative taxa diversity, with segment E exhibiting the highest relative diversity although fewer specimens were collected. Interestingly, no evidence of any fish species was noted within the channel segments slated for impact. A-7 ' Response to Public Notice Comments (P/N SAM-2007-200-359) September 25, 2007 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 Comment No. 9: The DWQ commented that Rosgen B streams are not considered degraded, and F stream are transitional. The DWQ requested that more detailed stream classifications be ' provided for the systems to be impacted. Response: In regard to comments provided by DWQ in Comment No. 9, we agree in concept ' that B-type streams are not degraded. However, B type stream can be in a state of disequilibrium. Stream disequilibrium eventually leads to a degraded state as environmental pressures from the adjacent watershed contribute to increased stream flows due to land ' application treatments; i.e., silvicultural operations. Such is the case of a majority of the streams proposed for impact within the subject property boundary. We also concur that, in general, F-type streams are transitional. We would presume that all streams are in a transitional state. The DWQ comments that F-type streams are transitional. Please note, however, that F-type streams are characterized by very high channel width/depth ratios and bedform features, or lack thereof, occurring as a moderated riffle/pool sequence. These stream channels can develop very high bank erosion rates, lateral extension rates, significant bar deposition and accelerated channel aegradation and/or degradation. F-type streams generally are not considered stable stream types. Due to the erosive state of some ' streambank areas, more stable downstream locations are primarily impacted by high sedimentation rates. ' In most cases where F-type stream segments were located, more stable B-type streams were located upstream and downstream of these degraded, transitional segments of F-type streams. In some cases it was clearly evident that previous logging practices have contributed to the degradation of these stream segments. The downstream portions of the channels are being impacted by sedimentation and the streambanks show signs of scour and moderate wasting. Stream No. 1 K in the northwestern portion of the property is transitioning from a stable stream to a state of disequilibrium prior to returning to a stable C-type stream in the lower portion of its reach. Based on visual observations and general measurements along the stream, the succession of stream types within the channel followed the Rosgen stream evolution process from a ' somewhat stable B-type stream to eventually an F-type and G-type stream before transitioning to a C-type stream just prior to leaving the subject property. ' Observational data, as obtained from the completion of the DWQ Stream Identification Form and the USACE Stream Quality Assessment Worksheet, were used to assimilate information on all streams within the subject property boundary. The data were analyzed to facilitate the determination of stream classification and the assessment of the quality of the aquatic habitat. A more detailed stream morphological assessment would not be expected to generate different results concerning the understanding of the current stream conditions onsite. ' Comment No. 10: With regard to the conclusion in the Individual Permit Application (IPA) that the development of the property is not likely to adversely affect small whorled pagonia, as based on the results of a field walkover, the DWQ responds that a "walkover" does not constitute a ' "survey." DWQ also recommended that a survey of all likely habitats by qualified personnel must be performed in order for the lead federal agency to make such a determination. ' Response: In regard to the potential for occurrence of threatened and endangered (listed) species to occur on the subject property, the USFWS, in a letter dated April 18, 2006, concurred with MACTEC's conclusions that no federally listed species are present on the site and that obligations under Section 7 of the Endangered Species Act have been fulfilled. A-8 ' Response to Public Notice Comments (PINSAM-2007-200-359) September 25, 2007 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 Comment No. 11: Application Information 5.1 states that the "subject site will potentially cause the project to fail to meet reasonable economic goals." As you have stated that the proposed impoundments are needed to achieve "reasonable economic goals," you must provide a thorough cost benefit analysis to support any claim that the impact is needed for the project to be ' "economically feasible." Analysis should include, but not be limited to, the construction costs of the dam, the cost of permitting (through all agencies including but not limited to the US Army Corps of Engineers, the Division of Water Quality, and the Division of Land Resources), the ' consulting costs (including environmental consulting costs and engineering costs), the costs of preservation (value of land after development) and the time-value of money vs. the anticipated financial gain in land values. ' Economic Cost Benefit Analysis enclosed (see Exhibit B). The permit applicant presumes that certain information should not be included in the response herein due to its sensitive and confidential nature and the potential for such information to be made available for public inspection during or after the permit review process. Some information is not available for inspection due to confidential client-consultant privileges. Comment No. 12: The DWQ states that the erosion control plan and the stormwater management plan are not interchangeable. The DWQ requests that FCLC develop a stormwater ' management plan which will provide for the management of any and all collected stormwater for the life of the project in order to protect water quality standards. Response: FCLC has provided an exemplary erosion control plan for the McDowell Lakes development. A stormwater management plan is being developed by TEC Environrnental as requested by DWQ to manage stormwater for the life of the project. The stormwater management plan is attached as Exhibit D. Comment No. 13: The DWQ states that conflicting information exists in the IP application regarding the proposed mitigation ratio for excellent streams; i.e. the mitigation ratio is variously reported as 3:1 and 1:1. Response: The mitigation ratio for excellent quality streams is 3:1. The value of l: l for the mitigation ratio for excellent streams that was reported in the IP application was erroneous. ' Comment No. 14: The DWQ requests that all streams within the property boundary be placed into legal protection under Section 15A NCAC 02H.0506 of the N.C. Water Quality Certification Rules, in order to protect them from collective impacts which would subject the applicant to further mitigation. Response: All proposed impacts have been documented in the January 17,. 2007 USACE IP application and discussed in the Alternatives Analysis section of the application. No other impacts are proposed or anticipated for this project. The FCLC is willing to provide a protective mechanism to protect the streams within the subject property that are not being considered or proposed for mitigation, if the DWQ is willing to provide some amount of additional mitigation credit to the project mitigation credit balance for this measure. Comment No. 15: The DWQ requests a breakdown of all intermittent and perennial impacts for ' the project. 1 A-9 ' Response to Public Notice Comments (PIN SAM-2007-200-359) McDowell Lakes Development Site, McDowell County, North Carolina September 25, 2007 MA CTEC Project No. 6229052914 Response: FCLC provided a detailed breakdown of all streams (intermittent and perennial) in Section 8 (Table 2) of the January 17, 2007 USACE IP application. With the exception of onl y a few streams, most perennial stream breakpoints were very distinct. A majority of the strea ms within the proposed impact areas started at the base of a headcut originating from an upstream ephemeral channel. MACTEC utilized the methodologies outlined in the technical document Identification Meth d o s for the Origins of Intermittent and Perennial Streams, Version 3.1 (dated February 29 2005) in d , etermining the intermittent/perennial break points on the subject property. Comment No. 16: The DWQ requests a lot layout. The DWQ also requests that the site lans b ' p e presented on full plan sheets. Response: the lot layout and site plans, as presented on full plan sheets, are attached as Exhibit E. Comment No. 17: The DWQ requests that all stream impacts including all fill slopes, dissipaters, and bank stabilization be show th i n on e s te plans. Response: The requested information, as presented on the site plans, is provided in Attachment E herein. ' Comment No. 18: Please locate all isolated or non-isolated wetlands, streams and other waters of the State as overlays on the site plan. Response: All Waters of the U.S. on the McDowell Lakes project site, including wetlands and streams, were delineated by MACTEC and verified by the USACE in a Notification of Jurisdictional Determination dated Januar 17 2006 T y , . he Jurisdictional Determination Request Package submitted to the USACE by FCLC on January 5, 2006 provided detailed maps indicating all jurisdictional wetlands and streams within the project boundary. Comment No. 19: The DWQ requests that cross section details showing provisions for aquatic life passa e be id d g prov e . Response: No impacts are proposed that would include road crossings or trails outside th e proposed footprint of the proposed lakes. Therefore, no provisions for aquatic life passage were provided in the site development lan Furth p . ermore, no Iisted aquatic species (primarily fish and macro-invertebrates) occur in the streams proposed for impact. With these considerati ons, the applicant presumes that cross section details showing provisions for aquatic life passage are not critical to the issu f h ance o t e Individual Permit. ' Comment No. 20: The DWQ requests that -any planned sewer lines be shown on the plans. Response: No sewer lines are proposed for the McDowell Lakes development. Comment No. 21: The DWQ has requested that FCLC specify the percent of impervious surface for the built-out conditions, and provide an inventory of the proposed project impervious surfaces if the percent of project imperviousness exceeds 20 percent. A-10 ' Response to Public Notice Comments (P/N SAM-2007-200-359) McDowell Lakes Development Site, McDowell County, North Carolina September 25.2007 MACTEC Project No. 6229052914 Res o M D p nse: r. avid Traylor of TEC Environmental has provided the Stormwater Mana ement Pl g an (see Exhibit D). U.S. Fish and Wildlife Service (USFWS In the USFWS letter dated March 15, 2007, various comments were presented, ranging from l genera comments to specific recommendations for the proposed project. The majority of the i tems of interest were initially identified during an inter-agency onsite meeting on August 14 2006. The attendees included representatives fr th WRC om e , the EPA, the USACE, DWQ, and MACTEC. For simplicity, each item of interest is individually addressed below. Comment No. 1: In the March 15, 2007 comment letter, USFWS stated that they opposed the construction of in-line structures such as the proposed lakes because they significantly alter both aquatic and terrestrial habitat. Response: While lakes and ponds may affect the loss of natural stream functions, they also can have a positive affect. The positive effects of water im oundme t i ' p n s can nvolve a reduction in the sediment transport and other non-point source pollutants, creating wildlife and.aquatic habitat, and providing for water stora e d g an supply during drought periods. The EPA provides case studies for urban runoff and provides numerous examples of how lakes and ponds can hel in d i 1 p re uc ng non-point source pollution. While the information provided highlights examples in urban settings the same functions n b i ca e ga ned in a residential development where potential run- off water may contain pollutants and sediment. The website for this information can b f e ound at hrtp://www.eDa uov/owow/nps/runoff htm197. Comment No. 2: In the letter from USFWS dated March 15, 2007, it is pointed out that USFWS do not believe the "Purpose and Need" t t s a ement in the IPA justifies the aquatic impacts associated with this project. Additionally, USFWS does not believe that fire su ressi h pp on s ould be considered when evaluating the purpose or need of a project. Response: Please see responses provided under USACE comment No. I and DWQ Comment No. 1. In regards to the comments made by USFWS, the FCLC disagrees with the assertion that fire suppression should not be considered when evaluating the need of this project considering a ' recent fire emergency at the project site. The need for fire suppression as stated previously is due to the lack of access to municipal utilities, including water. ' The FCLC worked with MACTEC scientists to develop, based on observed stream morphology and aquatic habitat using the USACE Stream Quality Assessment Worksheets and the DWQ Stream Identification Form (version 3. 1), to determine the best overall sites for development of the proposed impoundments. Streams exhibiting high quality aquatic habitat and generally stable geomorphology were excluded from consideration for the placement of the lake impoundments; in contrast, lower quality or unstable geomorphology were evaluated and eventually selected for the placement of the proposed lake impact areas. As requested by DWQ the client has also provided an aquatic biota study was completed documenting species throughout the proposed impact area (Exhibit C). Comment No. 3: In the USFWS letter, dated March 15, 2007, it was stated that, "we do not believe that the stated need for the lakes to provide recreational opportunities should be used to evaluate the purpose and need for the lakes". While reviewing the advertising web site for the ' development (hiip://,A,,.Nw.fallcreek-land.com /), we noticed that a large portion of the lots within A-1 I Response to Public Notice Comments (P/NSAM-2007-200-359) September 25, 2007 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6129052914 1 I 1 1 11 1 the development have already been sold or are under contract. The USFWS further comments that the website contradicts the IPA with regard to the need for the proposed lakes by not mentioning the proposed lakes on the website. Response: The proposed lakes will provide onsite recreational including swimming, kayaking, canoeing, and fishing opportunities to the residents of the development. The FCLC is faced with a competitive real estate market that provides on-site amenities to clients. The need for the lakes as a recreational amenity comes from a comparison of developments around Lake James and Lake Lure which compete with the FCLC development. Therefore, FCLC has to take in consideration the real market competition for home buyers within the region, including the sector of home buyers which desire onsite, water based, and recreational amenities. Finally, the FCLC will review their website to determine the appropriate language to add regarding the proposed two lake features at the McDowell Lakes development. Comment No. 4: In the letter, dated March 15, 2007, USFWS commented that the mitigation plan does not adequately compensate for the impacts this project will have on aquatic resources. Response: Based on the results of the Aquatic Biota study for the subject property, no listed aquatic species occur in the streams proposed for impact. Critical habitat for listed aquatic species is either not present or greatly lacking. Some generalist (non-listed) aquatic species may be impacted by the filling of onsite stream reaches; however, the applicant believes the proposed mitigation plan adequately compensates for the loss of habitat of the affected species. N.C. Wildlife Resources Commission (WRC) In the WRC letter dated March 12, 2007, various comments were presented, ranging from general comments concerning the habitat types to specific recommendations for the proposed project. Some of the items of interest were initially identified during an inter-agency onsite meeting on August 14 2006. The attendees included representatives from the United States Fish and Wildlife Service (USFWS), the Environmental Protection Agency (EPA), the USACE. DWQ, and MACTEC. For simplicity, each item of interest is individually addressed below. Comment No. 2: The WRC recommended that a 404 Permit and 401 Certification not be issued for three primary reasons, the first reason regarding reduced stream quality Response: The FCLC understands the comments regarding reduced stream quality from the construction of the lakes. However, FCLC, suggests that the creation of impoundments on the project site will create deep water holding areas or access to impounded waters in lakes or ponds for streams throughout the year. In many instances the habitats of both fish and invertebrates can be devastated by a lack of flowing water due to upstream use or prolonged drought conditions. As discussed in the IPA, on page 37, a dam design allowing for release of water (i.e. 7Q10) during all but the most severe drought conditions will be constructed providing a stable flow regime which can increase stream habitat quality. Stream quality will be provided a constant water release that will provide fewer fluctuations in water temperature, potentially reduced fluctuations in water chemistry, and a controlled and stable in-stream sediment transport which may further reduce the in-stream degradation of bed features and aquatic habitat. During the construction of the lakes a considerable amount of earthwork will be performed. FCLC will utilize appropriate BMPs in guidance provided by the State Stormwater Management Program to reduce any potential for erosion and sedimentation downstream of the construction A-12 Response to Public Notice Comments (P/N SAM-2007-200-359) September 25, 2007 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052974 area. A stormwater management plan is attached in Exhibit D (To be provided by the client prior to submission). ' Comment No. 2: The WRC recommended that a 404 Permit and 401 Certification not be issued for three primary reasons, the second reason regarding the elimination and fragmentation of habitat. Response: FCLC agrees that the proposed impacts will reduce and fragment aquatic stream and wetland habitat within the proposed lake impoundment areas. Habitat fragmentation creates landscapes made of altered habitats or develo ed areas fund t ll diff f p amen a y erent rom those shaped by natural disturbances that species have adapted to over evolutionary time (Noss and Cooperrider 1994. Historical landuse of the development has been primarily silviculture and to some extent mining. Alteration and fragmentation of the aquatic and terrestrial habitats on the project site have been a continual process for over 50 years. Evidence of silviculture and mining are demonstrated on the project site by stream crossings with inadequate culvert placement that has disconnected the upstream portions of a majority of first order streams in the proposed impact areas along with evidence of the manipulation of stream channels by altering or relocating the stream from its historical channel. Apparent gold mining along the streams using techniques ' such as sluicing appear to have created "pits" in the riparian areas that have since become spring seep wetlands. In many instances lakes and ponds can interact with streams with very positive results. Replacement of the loss of the geomorphologically degraded streams and wetland habitat with a lake may potentially enhance on-site aquatic resources. Results can range from providing holding habitats during drought or extreme runoff periods, create an expanded littoral zone which may enhance biodiversity of amphibian and macroinverterbrate species, create habitat for neotropical migrant bird species, and waterfowl habitat. Based on a survey of the impact areas, dated April ' 11, 2007, no fish were captured in the streams being proposed for impact. Comment No.3: The WRC recommended that a 404 Permit and 401 Certification not be issued for three primary reasons, the third reason regarding inadequate compensatory mitigation. Response: The mitigation plan was revised on May 30, 2007. For impacts associated with dam construction, FCLC proposes a 1:1 ratio for impacts to 375 Lf of stream channel. FCLC proposes mitigation for proposed fill impacts of on-site stream channels by making payment to the NC EEP in the amount necessary to restore 375 feet of stream channel in the Catawba River ' basin. The payment into NCEEP is proposed to compensate for impacts associated with dam construction to 375 linear feet of stream channel at a 3:1 ratio. Additionally, mitigation for the flooding of 6,412 linear feet of stream is proposed by preserving approximately 12,535 linear feet of stream channel with an approximately 120-foot wide riparian buffer (approximately 34 ' acres). The FCLC is willing to provide a protective mechanism to protect the additional 47.605 If of undisturbed streams within the subject property that are not being considered or proposed for mitigation, * if the agencies are willing to provide some amount of additional mitigation credit to the project mitigation credit balance for this measure. If the agencies agree, approximately 47,605 linear feet of stream channel will remain undisturbed with a 120-foot riparian buffer (approximately 131- acres). The applicant is proposing to preserve these additional areas in perpetuity using a deed restriction or other approved preservation mechanism. A-1.3 Response to Public Notice Comments (PAN SAM-2007-200-359) September 25, 2007 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 ' Wetland mitigation will be undertaken by purchasing 1.2 acres of wetland restoration from the NCEEP In-Lieu Fee Program. ' North Carolina Natural Heritage Program (NHP) Comment No. 1: In a letter dated, March 12, 2007, N-IP acknowledges that no species listed for the Muddy Creek area were identified within the boundary of the proposed development and further pointed out that this may be due to the area not being surveyed by NHP staff. or ' contributing biologists. NHP further recommended that careful surveving and planning to avoid impacts to rare species or habitats be employed. Response: In regard to the potential for occurrence of threatened and endangered (listed) species to occur on the subject property, the USFWS, in a letter dated April 18, 2006, concurred with MACTEC's conclusions that no federally listed species are present on the site and that obligations under Section 7 of the Endangered Species Act have been fulfilled. In a letter, dated February 28, 2006, NHP indicated that it had no record of significant natural communities or priority natural areas at the site nor within a mile of the development. The NET did indicate on rare species known from within the project boundary - The Alabama grape-fern (Botrychium jenmanii). No occurrence of this species was recorded by MACTEC scientists during a survey of the project area. Comment No. 2: The NIP also commented that the proposed mitigation b reserv by p atron of other streams would be unlikely to protect comparable rare plant habitat and natural communities. Response: In a letter, dated February 28, 2006, the NHP indicated that it had no record of ' significant natural communities or priority natural areas at the site nor within a mile of the development. ' North Carolina Department of Cultural Resources - (SHPO) In a letter dated, March 8, 2007, SHPO requested that the project area be surveyed by an experienced archeaologist to identify and evaluate the significance of archaeological remains that ' may be damaged or destroyed by the proposed project. Response: MACTEC archaeologists conducted a Phase I Cultural Study of the proposed impact area. Between May 21 and 25, 2007, MACTEC carried out a Phase I archaeological survey on land proposed for the formation of two lakes within the development area. Based on a literature review of the NRHP records and the Phase I archaeological survey no Previousl ?-recorded archaeological resources or new sites were recorded as a result. The findings of this study were provided to the North Carolina State Historic Preservation Office in a report dated June 25, 2007. The resulting report and findings are attached as the Exhibit F attachment. CONCLUSION The applicant's efforts to avoid and minimize impacts to natural resources have been competent and well documented. The IPA document presents the alternatives analysis, minimization, site layout and design, and compensatory mitigation. The various concerns that have been brought I A-14 1 0 1 1 0 0 L 1 Response to Public Notice Comments (P/N SAM-2007-200-359) McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 September 25, 2007 forth by the state and federal agencies in regard to the development of the site have been addressed in the responses herein. CLOSING We hope this response to these comments will provide the USACE with an explanation of design parameters associated with this project and grounds necessary for its approval. Please contact Robert L. Sain at (828) 252-8130 or Allen W. Conger at (803) 798-1200 if you have any questions regarding this information. Sincerely, MACTEC ENGINEERING AND CONSULTING, INC. A)0'1 Robert L. Sam Allen W. Conger, PWS Project Scientist Senior Principal Scientist for ?' with permission Enclosure: Exhibit A - N.C. Division of Forest Resources (NCDFR) Letter Exhibit B - Comparative Market Analysis with Lot listings Exhibit C - Aquatic Biota Report Exhibit D - Stormwater Management Plan Exhibit E - Site Plan Sheets Exhibit F - Phase I Archaeological Survey of McDowell Lakes development (Formerly McDowell County Lakes Project), Nebo, North Carolina. A-15 Response to Public Notice Comments (P/N SAM-2007-200-359) McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6129052914 EXHIBIT A N.C. Division of Forest Resources (NCDFR) Letter September 15, 2007 A-16 North Carolina Al Department of Environment and , 71 Natural Resources NCDENR Michael F. Easley, Governor i FOREST SERVICE N C 1 William G. Ross Jr., Secretary * McDowell County Forest Ranger N.C. Division of Forest Resources 139 College Drive Marion, N.C. 28752 Phone: (828) 652-2636 ' E-mail: mcdowell.dfr@ncmail.net ' June 1, 2007 Todd Black Fall Creek Land Company ' P.O. Box 638 Hickory, N.C. 28603 ' Dear Mr. Black: North Carolina Division of Forest Resources Wib L. Owen, Director You are interested in establishing one or two lakes in the Grandview Peaks housing ' development located in the Dysartsville community here in McDowell County. The North Carolina Division of Forest Resources assist private individual landowners, developers, and local planning boards with information and recommendations on forest ' fire prevention and control though the North Carolina Firewise Program. I have outlined some key points below on reasons why we support your effort to install lake(s) in the Grandview Peaks development. Everyone knows that fire control in rural areas requires water. Fires in these areas can be especially difficult to control since there is not an organized system of main water lines and fire hydrants. Control of a fire is affected by how long it has been burning and then by the "rate-of-application" of the water. Assuming a limited availability of mobile water supply vehicles, it is easy to see that long transportation distances to some water sources ' results in longer time frame between applications of water. To deal with the problem of distance, water tenders are used to transport water. This system will bring water to the fire but it is inefficient and time-consuming. The closest "water point" for firefighting ' vehicles responding to Grandview Peaks is approximately five miles from the entrance to the development. ' Using natural water sources, such as streams, lakes, or ponds provides a relatively inexpensive quantity of water. Streams tend to offer lower quantities of water and have reliability issues. ' A lake or series of lakes within the Grandview Peaks development would solve the problem of a close and reliable water source for firefighting. ' 1616 Mail Service Center, Raleigh, North Carolina 27699-1601 Phone: 919 - 733-2162 \ FAX: 919 - 715-4350 \ Internet: www.dfr.state.nc.us AN EQUAL OPPORTUNITY \ AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED / 10% POST CONSUMER PAPER ' We encourage you as a developer and the residents within Grandview Peaks t y to ' investigate the benefits of the North Carolina Firewise Program. A comprehensive proactive fire mitigation plan can be prepared to assist with long-term fire planning. The N.C. Division of Forest Resources also provides FireWise education programs to ' development/homeowner groups. I have listed some additional information sources below. Please feel free to contact me direct at the number listed above if you have any questions reference this letter or FireWise planning. Sincerely: John Reese ' McDowell County Forest Ranger Reference: National Fire Protection Association publication, NFPA 1231 Standard on Water Supplies for Suburban and Rural Fire Fighting. ' North Carolina Firewise Program www.ncfirewise.org cc: Ron Spears, MACTEC Engineering 0 1 Visit Our Web Site at: www.dfr.state.nc.us ' Response to Public Notice Comments (P/N SAM-2007-200-359) McDowell Lakes Development Site, McDowell County, North Carolina MA CTEC Project No. 6229052914 ' EXIIBIT B Comparative Market Analysis September 25, 2007 Grandview Peaks Projections Proposed lots : 699 Lots developed : 189 Lots sold : 128 (18%) Projected sellout with lakes: $56,744,340 ( 74 lakefront lots & 37 lake view lots ) Projected sellout without lakes : $49,289,340 Sellout difference : $7,455,000 Lake construction cost : $950,000 Engineering & Consulting : $350,000 Permit Fee's : $300,000 estimate Net difference: $5,855,000 LD 0 T Y Q 'a F- 1W / 0O J z w /v oio oo oPOboio ofo ot 00 1 IO1030 O{O Ot ? i l Z oio{oio Oi0i0{O p 81810 1010iN10 oIOtO€0 1 i 0 0 03:O OlOtOiO O N OV ay< N M M101 cD 0jIM OgOD O?90 O? OlIOfO?#O!O! OQ? q Gi 0 40I01 O?I07 G0 0f 0 0? CIUM 0IQ1{O€O O 00 cj? 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M IM q 1C4 NfNiN ir IMIM §PliM{MiM9M11?lMletPettVIOW }'1vvlef??tid4d €e!i'?d4et;?:etlbI?ft1!el V Response to Public Notice Comments (P/N SAM-2007-200-359) September 25, 2007 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 1 EXHIBIT C Aquatic Biota Report 1 A-18 D 1 1 23 April 2007 Fall Creek Land Company PO Box 638 Hickory, NC 28603 Attn: Mr. Todd Black RE: Grandview Peaks - RAI Response Task 13 McDowell County, North Carolina ESI Project Number EE07-013 Dear Mr. Black: Environmental Services, Inc., (ESI) has completed the aquatic evaluation within the five (5) stream segments at the Grandview Peaks development site located in McDowell County, North Carolina (Figure 1). The evaluation was conducted as part of a Request for Additional Information from the N.C. Division of Water Quality (DWQ). This letter serves as the deliverable for this project. The stream segments are identified as segments A, E, C, M, and K on mapping supplied to ESI. Key Personnel The study was conducted on 2-3 April 2007. The macrobenthic survey was conducted under the direction of Gail Tyner. Ms. Tyner is a Senior Scientist with more than 9 years of professional experience, and has completed the training by the State to conduct QUAL 4 collections following the prescribed method as defined in the DWQ Benthic Macroinvertebrate Monitoring Protocols for Compensatory Stream Restoration Projects. The fishery sampling was conducted under the direction of Kevin Markham. Mr. Markham is a Senior Scientist with more than 19 years of professional experience, including experience conducting fisheries sampling across the State of North Carolina. Other ESI personnel involved in the collection effort include Jeff Benton (4 years of professional experience), Gavin Blosser (4 years of professional experience), and John Metrailer (2 years of professional experience). Methods The collection effort targeted five stream channel segments within the Grandview Peaks development slated for impact. Due to the overall length of segment C, two surveys were conducted, one in the upper reach (above the confluence with segment A) and one in the lower reach (below its confluence with segments A and E). To document macroinvertebrates each stream channel segment was surveyed using the QUAL 4 collection method. The QUAL 4 collection method includes one (1) kick net from riffles; one (1) sweep net from banks, one (1) leaf pack sample, and a visual of semi-permanent structures within each stream channel reach. The collected macrobethos were identified to Order, with diversity and abundance detailed by reach. n To document fish species, a back-pack electro-shock unit was initially proposed for use. However, due to the small size and shallowness of the stream channels to be surveyed, seining and dip-netting were used as an alternative survey method. Visual surveys of the channels were conducted in conjunction with the macrobenthic survey. Results Good water quality is closely associated with a high richness of taxa. Increasing levels of pollution gradually eliminate the more sensitive species, leading to a lower overall species of taxa richness. Table 1 indicates the relative abundance of each order documented within each stream reach. Table 1. Macrobenthos abundance in stream segment samples Macrobenthos Order Relative Abundance b Stream Segment' C C A E K M (Lower) (Upper) Oligochaeta (Segmented Worms -- -- P -- Gastropoda A A A A P A Snails Ephemeroptera A A A C A A (Mayflies) Odonata (Dragonflies/damselflies) P P P C A C Plecoptera C A C C P A Stoneflies Megaloptera (Dobsonflies/alderfl ies) P -- P Trichoptera C A A C C C (Caddisflies) Coleoptera P P P P -- P (Beetles) Diptera (True Flies P C P P P P Crustacea P P P P P P (Crayfish and kin) a Abundant >30 individuals; Common 10-29 individuals; Present <9 individuals; -- none found. Taxa abundance and diversity at the ordinal level was relatively high within all stream reaches sampled. The Orders Ephemeroptera, Plecoptera, and Trichoptera (EPT) are particularly sensitive to water quality and the presence of individuals of these taxa and the diversity of the taxa present collectively can be used as an assessment tool. Ephemeroptera exhibited the highest abundance within all stream channels sampled, with Plecoptera and Trichoptera generally second and third; the EPT were each Common to Abundant at the stations sampled. EE07-013 Other insect Orders noted in the macrobenthos samples include Odonata, Megaloptera, Coleoptera, and Diptera. These Orders generally did not exhibit high relative abundance, with the exception of Odonata in channel segment K. Other macrobenthic groups present included Gastropoda, Oligocheata, and Crustacea. All stream segments sampled exhibited high relative taxa diversity, with segment E exhibiting the highest relative diversity. All stream segments exhibited moderate to high relative abundance of the EPT taxa, which generally indicates good water quality. The stream channels proposed for impact each exhibited a relatively high abundance and diversity of macrobenthos taxa, also indicating relatively good water quality. No evidence of any fish species was noted within the channel segments slated for impact. Several individuals of one species, rosyside dace (Clinostomus funduloides), were documented approximately 300 feet downstream from the proposed impact area in Stream Segment M. These individuals were noted in a relatively large, deep pool below the confluence of several side tributaries. No similar habitat was identified within the stream segments proposed for impact. Environmental Services, Inc., appreciates the opportunity to offer you our services. If you have any questions or comments, or need any additional information, please feel free to contact me at 828- 254-0811 or Gail Tyner at 919-212-1760. Sincerely, ENVIRONMENTAL SERVICES, INC. Jan Gay Asst. Vice President Attached: Figure 1 Cc: R. Spears, MACTEC EE07-013 Response to Public Notice Comments (P/N SAM-2007-200-359) McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 EXHIBIT D Stormwater Management Plan September 25, 2007 A-19 PROJECT STORMWATER MANAGEMENT GRANDVIEW PEAKS ' McDowell County, NC I The following describes stormwater management for the project: The Erosion and Sedimentation Control Plan prepared by Lewis N. Cox, PLS will be followed during all construction activities. Thereafter, the following requirements for low-density residential development will apply and will be maintained for the life of the project: • The development will be restricted to a built-upon area of 12% or less with residential development on lots of one acre or greater. • There will be no discrete stormwater collection system for the project. Stonnwater runoff will be transported by natural swales and vegetated conveyances. Swales will not be filled in, piped, or altered except as necessary to provide driveway or roadway crossings. • During the construction of home sites, where mitigation has been proposed, a sixty-foot buffer will be maintained and protected on each side of the surface water. ' Response to Public Notice Comments (P/N SAM-2007-200-359) McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 ' EXHIBIT E Site Plan Sheets September 25, 2007 ' Response to Public Notice Comments (P/N SAM-2007-200-359) September 25, 2007 McDowell Lakes Development Site, McDowell County, North Carolina MACTEC Project No. 6229052914 EXHIBIT F DRAFT Phase I Archaeological Survey of McDowell Lakes development (Formerly McDowell County Lakes Project), Nebo, North Carolina. A-21 PHASE I ARCHAEOLOGICAL SURVEY GRANDVIEW PEAKS DEVELOPMENT FORMERLY MCDOWELL COUNTY LAKES PROJECT NEBO, NORTH CAROLINA Prepared For: Fall Creek Land Company Post Office Box 638 Hickory, North Carolina 28603 Prepared By: A-`M.LA1L%CTEC MACTEC Engineering and Consulting, Inc. 1725 Louisville Drive Knoxville, Tennessee 37921 MACTEC Project 6229-05-2914 By: LaDonna A. Rogers Paul G. Avery, RPA - Principal Investigator June 22, 2007 AMACTEC engineering and constructing a better tomorrow September 25, 2007 Mr. Todd Black Fall Creek Land Company P.O. Box 638 Hickory, NC 28603 Subject: Report of Phase I Archaeological Survey Grandview Peaks Development Formerly McDowell County Lakes Project Nebo, North Carolina MACTEC Project 6229-05-2914 Dear Mr. Black: ' We are pleased to submit this report of our archaeological investigation for the above referenced project. The purpose of our survey was to determine if significant cultural resources were located within the proposed location for Lakes 2 and 3 in the Grandview Peaks Subdivision in McDowell ' County, North Carolina. This report has been submitted to the North Carolina Office of State Archaeology for regulatory review. Their office has 30 days to review the report, at which time they will issue a letter with any comments. We will notify you as soon as this letter is received. This report is intended for the use of Fall Creek Land Company subject to the terms and Conditions agreed upon between MACTEC Engineering and Consulting, Inc., (MACTEC) and Fall Creek Land Company. The contents should not be relied upon by any other party without the express written consent of MACTF.,C. This report presents project information, which includes our assessment procedures and our findings, conclusions, and recommendations. Use of this report for purposes beyond those reasonably intended by Fall Creek Land Company and MACTEC will be at the sole risk of the user. Mr. Black, we appreciate your selection of MACTEC for this project and we look forward to assisting you with other work. If you have any questions, please contact us at your convenience. Sincerely, MACTEC Engineering and Consulting, Inc. 102 LV . Rogers Archaeologist to prnu?a ?a for LAR/PHG:mly with Permission Enclosure Patrick H. Garrow, RPA Principal Scientist MACTEC Engineering and Consulting, Inc. 1308 Patton Avenue 0 Asheville, NC 28806 41 Phone: 828.252.8130 0 Fax: 828.251.9690 www.mactec.com MANAGEMENT SUMMARY Between May 21 and 25, 2007, MACTEC Engineering and Consulting, Inc., (MACTEC) carried out a Phase I archaeological survey on land proposed for the formation of two ' lakes within the Grandview Peaks Subdivision in McDowell County, North Carolina. The construction of the two lakes will encompass approximately 35 acres of land, 0.6 acre of which are wetlands. Approximately 7,330 linear feet (or 2.234 meters) of stream ' will be impacted. The project area is situated in the northwestern part of the subdivision, which is located off Joe Branch Drive, southeast of Dysartsville in McDowell County, North Carolina. This work was carried out by two of MACTEC's staff (LaDonna A. Rogers and Neal R. Engel). No previously-recorded archaeological resources were noted within the project area, and ' no National Register of Historic Places-listed properties were present. However, one new archaeological site (31MC340) was recorded as a result of this survey. ' TABLE OF CONTENTS Page MANAGEMENT SUMMARY ....................................................................................................... ii LIST OF FIGURES ........................................................................................................................ iv LIST OF TABLES .......................................................................................................................... iv 1. INTRODUCTION ................................................................................................................... 1 Project Description ...................................................................................................1 II. GEOLOGICAL AND ENVIRONMENTAL SETTING ......................................................... 4 111. CULTURAL BACKGROUND ............................................................................................... 7 Prehistoric Background ............................................................................................7 Paleoindian (10000-8000 BC) ...............................................................................7 Archaic (8000-1000 BC) ..........................................................................................7 Woodland (1000 BC-AD 1000) ............................................................ ............7 ....... Mississippian (AD 1000-1540) ............................................ Historic Cherokee (AD 1540-1838) .........................................................................8 Historic Period (AD 1540 to Present) ......................................................................8 Previous Archaeological Investigations ...................................................................9 IV. METHODS ............................................................................................................................10 Field Methods ........................................................................................................10 Lab Methods ......................................................................... ....................10 V. RESULTS ......................................................................................... .....................13 ................ VI. RECOMMENDATIONS AND CONCLUSIONS ................................................................ 16 VII. REFERENCES ..................................................................................................................... 17 APPENDIX A: SHOVEL TEST DATA APPENDIX B: STATE SITE FORM (31MC340) ii LIST OF FIGURES Page 1. Project Area Map, area of Potential Effect consists of proposed lake boundaries........ 2 2. Vegetation along Stream `E' ........................................................................................ 11 3. Vegetation on slope along Stream `E' ......................................................................... 11 4. Slope along Stream in Lake 3 ...................................................................................... 12 5. Slope along Stream `E' in Lake 2 ................................................................................ 12 6. Shovel Tests Associated with Lake 2 .......................................................................... 14 7. Shovel Tests Associated with Lake 3 .......................................................................... 15 LIST OF TABLES Page 1. Cowee series soils .......................................................................................................... 4 2. Evard series soils ............................................................................................................ 5 3. Hayesville series soils .................................................................................................... 5 4. Iotla series soils .............................................................................................................. 5 ii I. INTRODUCTION MACTEC Engineering and Consulting, Inc. (MACTEC) was contracted by Fall Creek Land Company (FCLC) to conduct Phase I archaeological investigations at the proposed locations of two new lakes within the Grandview Peaks Subdivision (Figure 1). The construction of these lakes will involve the alteration of a series of streams in the northwestern part of the property. The goal of this survey was to locate and identify archaeological resources within the project area and to evaluate the eligibility of any encountered sites for inclusion on the National Register of Historic Places (NRHP). The field survey began on May 21, 2007 and was completed on May 25, 2007. Mr. Paul G. Avery served as Principal Investigator (Archaeologist in General Charge) and LaDonna A. Rogers served as Field Director (Archaeologist in Direct Charge) for the project. MACTEC Principal review was provided by Mr. Patrick H. Garrow. Ms. Rogers was assisted in the field by MACTEC employee Neal R. Engel. Our fieldwork was conducted in accordance with the National Historic Preservation Act of 1966, as amended, and its implementing regulations (36 CFR Part 800, as revised), and the Archaeological Resource Protection Act of 1979. The survey and its resulting technical report were executed according to the guidelines provided by the North Carolina Office of State Archaeology (OSA). Our scope of work was formulated in consultation with OSA, and included shovel testing at 30-meter intervals in areas with less than 15% slope (including both the tops of ridges and along stream beds) and pedestrian examination of all other areas. All project related materials will be permanently curated by an OSA-approved facility. Project Description This project involves the construction of two lakes within the Grandview Peaks subdivision. The APE consists of the area of the two proposed lakes in the northern part of the subdivision. The construction of the two lakes will encompass approximately 35 acres of land, 0.6 acre of which are wetlands. Approximately 7,330 linear feet (or 2,234 meters) of stream will be impacted. The project area is situated in the northwestern part of the subdivision, which is located off Joe Branch Drive, southeast of Dysartsville in McDowell County, North Carolina, and is covered by mixed woods along the banks of the creeks and on the tops of ridges. The project area was accessed by both paved and dirt roads that have been constructed for use within the subdivision. The footprints of the project areas (Lakes 2 and 3; see Figure 1) encompass unnamed tributaries of Hoppers Creek and South Muddy Creek, steeply-sloped ravines and relatively level ridge tops. Figure 1. Project Area Map, area of Potential Effect consists of proposed lake boundaries. 2 II. GEOLOGICAL AND ENVIRONMENTAL SETTING ' The Grandview Peaks Subdivision is located in McDowell County, North Carolina, which is located in the western part of the state and straddles the Piedmont and Blue ' Ridge Mountains physiographic provinces. A large part of the county (nearly two-thirds) falls within the Piedmont province, and this includes most of the area east of the Blue Ridge Escarpment. The Blue Ridge province is characterized by rugged terrain while the ' Piedmont is characterized by a rolling topography that includes peaks, ridges, coves and valleys (NCNHP 2005:1). Elevation in the county ranges from approximately 329 meters (or 1,080 feet) along the McDowell-Burke county line at the Catawba River to approximately 1,726 meters (or 5,665 feet) at Pinnacle near the southern limit of the Black Mountains. Most of McDowell County is within the Catawba River basin. McDowell County encompasses a total of 283,000 acres, and of this area 237,720 acres (84%) are considered to be forest land. In 2004, only 4,800 acres of active harvested cropland were recorded, and this accounted for less than two percent of the total landmass of the county (NCNHP 2005:1). In 2005, an inventory of McDowell County identified 35 `Significant Natural Heritage ' Areas' within the county. The project area lies within the South Mountains-Blue Ridge Landscape Connection very close to the Lone Mountain Natural Area (NCNHP 2005:1-4). The project area includes a variety of soils. The major soils found within the project area are the Cowee, Evard, Hayesville, and Iotla soil series. Cowee series soils are located on ridges and slopes ranging from 2 to 95 percent and are typically identified at elevations ranging from 427 meters (or 1,400 feet) to 1.219 meters (or 4,000 feet). These soils are moderately deep, well-drained, moderately permeable and are of the fine-loamy taxonomic class. The typical pedon is represented in Table 1 (USDA 2006). Table 1. Cowe(-. ceriPC cn;lc m De th (curbs) Description 0-5 Organic material 7 5-18 Reddish brown gravelly sandy loam Bt2 18-38 38-73 Red gravelly sandy clay loam Red grav elly sandy clay loam Cr cmhs = eentimat- hale. 73-157 ....... r- Multicolored hornblende gneiss ricyaicu nyiuate: L)K b/14/07 Checked By/Date: PHG 6/15/07 The Evard series soils are located along ridges and on side slopes of the Blue Ridge that range from 2 to 95 percent. They are typically found at elevations ranging from 427 meters (or 1,400 feet) to 1,219 meters (or 4,000 feet). These soils are very deep, well-drained, moderately permeable and of the fine-loamy taxonomic class. The main soil texture of the series is sandy loam, but the deeper soils are of saprolite (decomposed rock). The typical pedon for the Evard series soils is represented in Table 2 (USDA 2006). 4 Table 2. Evard serieq snila Stratum Depth (cmbs) Description A 0-5 Very dark grayish brown sandy loam E 5-13 Brown fine sandy loam Btl 13-23 Strong brown fine sandy loam Bt2 23-74 Red sandy clay loam BC 74-94 Red very fine sandy loam Cl 94-124 Yellowish red loamy fine sand/saprolite C2 124-183 Reddish brown loamy fine sand/saprolite rrepared By/Date: DR 6/14/07 Checked By/Date: PHG 6/15/07 The Hayesville series soils are very deep and well-drained soils that are located in areas that vary from gently-sloping to very steep ridges with slopes that range from 2 to 60 percent. These soils are typically found at elevations ranging from 427 meters (or 1,400 feet) to 1,219 meters (or 4,000 feet) (USDA 2006). The typical pedon for the Hayesville series soils is represented in Table 3. Table 3. 14avewillP cPriec mile Stratum Depth (cmbs) Descri tion Al 0-3 Brown loam A2 3-13 Brown loam BA 13-23 Yellowish red clay loam Btl 23-66 Red clay Bt2 66-97 Red clay loam BC 97-122 Yellowish red and red sandy clay loam C 122-152 Strong brown fine sandy loam/saprolite rreparea tsy/Late: UK 6/14/07 Checked By/Date: PHG 6/15/07 The Iotla series soils are very deep, somewhat poorly-drained and moderately permeable soils found on nearly level (0 to 3 percent slope) flood plains in the southern Blue Ridge Mountains (USDA 2006). This is the least abundant soil type within the project area. The typical pedon for the lotla series soils is represented in Table 4. Table 4. Iotla Seri e.q -,oil,, Stratum Depth (cmbs) Description 0-20 Brown loam 20-48 Dark yellowish brown sandy loam J 48-79 Brown loam 79-119 Dark grayish brown sandy loam 119-135 Grayish brown loamy sand ')Cg 135-170 Grayish brown very gravelly sand rreparea 13y/Gate: DR 6/14/07 Checked By/Date: PHG 6/15/07 5 G' ' The vegetation covering the project area varies depending on elevation, but generally the project area is forested. The dominant species include oak and pine with an understory ' that includes flowering dogwoods, mountain laurel, flame azalea, and rhododendron (USDA 2006). The animal population consists of a wide variety of mammal species, including deer, squirrel, raccoon, and rabbit. Additionally numerous reptiles, amphibians, and avian species inhabit the project area. Very few animals were encountered in the project area ' during the survey, and it is likely that this is due to the nearby construction of houses in the subdivision. r 1 u u 11 t III. CULTURAL BACKGROUND This chapter presents the prehistoric and historic contexts of the project area. The discussion will cover a chronology of five periods: Paleoindian (12000-8000 BC), ' Archaic (8000-1000 BC), Woodland (1000 BC-AD 1000), Mississippian (-AD 1000- 1540 and Historic (AD 1540-present). ' Prehistoric Background ' The prehistoric background of the project area can be divided into four general categories that have unique cultural characteristics. These periods are the Paleoindian, Archaic, Woodland, and Mississippian periods, and each of these will be briefly discussed below. Paleoindian 10000-8000 BC The earliest well-documented human occupation of southeastern North America occurred during the Paleoindian period. Key diagnostic artifacts recovered from Paleoindian contexts include fluted and unfluted lanceolate projectile points. Since the vast majority ' of artifacts dating to this period are recovered as surface finds, it has been difficult to make inferences concerning social organization and subsistence during the Paleoindian period. However, it is generally accepted that these populations were highly mobile with ' small temporary settlements (Webb 2002:15). Archaic (8000-1000 BC) The identification of Archaic sites relies heavily on the typology created for projectile points of this period. Generally, Archaic populations are described as foraging populations that hunted, fished and made use of wild plant resources. The Archaic period experienced an increase in population and, as a result, an increase in recovered archaeological remains is noted. The Archaic period is divided into three sub-periods (i.e. Early, Middle, and Late). Early Archaic period (8000-6000 BC) projectile points include Corner Notched and bifurcate-based types such as St. Albans, LeCroy, and Kanawha points, which range in date from 6900 BC to 5800 BC. The Middle Archaic period (6000-4000 BC) saw increasingly diversified subsistence patterns along with the onset of stemmed rather than notched projectile points and an increase in the use of ground stone tools. The Middle Archaic period is further subdivided in North Carolina, and these subdivisions include Stanley (6000-5000 BC), Morrow Mountain I and II (5000-4200 BC), and Guilford (4200-3500 BC) (Webb 2002:16). Woodland (1000 BC-AD 1000) The Woodland period is marked by the apparent widespread use of pottery. In addition to this, there is an increased importance placed on horticulture, an elaboration in 7 k mortuary practices, and an increase in sedentism. The hunter-forager practice continues, but there is an increased emphasis placed on the cultivation of native plants during the Woodland period. The Woodland period is divided into three sub-periods: Early Woodland (1000-400 BC), Middle Woodland (400 BC-AD800), and Late Woodland (AD 800-1000). The Early Woodland period remained largely unchanged from the Late Archaic period, but the Middle Woodland period saw the intensification of long-distance trade with North Carolina groups participating in the Hopewell exchange network. Diagnostic ceramics during the Middle Woodland period include the Pigeon series, which is check-stamped, simple-stamped, plain, brushed, and complicated-stamped. There is also the Connestee series pottery that is thin, sand-tempered, and exhibits simple-stamped or brushed decoration. The Late Woodland period saw the establishment of sedentary villages based on horticulture (specifically the production of maize) as well as the development of complex tribal and chiefdom-level political systems. Unlike the preceding periods, there is a lack in diagnostic material to identify this period precisely in the archaeological record (Webb 2002:17). Mississippian (AD 1000-1540) The early part of the Mississippian period in western North Carolina is known as the ' Pisgah phase (AD 1000-1450). Diagnostic artifacts of this period include small, triangular projectile points and plain, complicated stamped, and check stamped ceramics. Analysis of floral and faunal remains from Mississippian sites shows that wild plants and animals continued to be important food sources in spite of advances made in horticulture (Webb 2002:16). Historic Cherokee (AD 1540-1838) The Historic Cherokee period is defined by the first European contact during the mid 16th century. In western North Carolina, this is known as the later Qualla phase (AD 1650- 1838), whereas the material culture of the early Qualla phase (AD 1450-1650) may ' simply represent a continuation of material culture types of the earlier Pisgah phase. Most early Qualla pottery is complicated stamped, while the later Qualla phase is predominantly check stamped. The subsistence patterns during the Historic Cherokee period included the cultivation of plants such as maize and beans, along with the gathering of wild plants, hunting, and fishing. The later Qualla phase is also marked by the appearance of European goods within archaeological contexts, along with the use of Euro-American structure styles. During the 18th century, there was a general shift away from nucleated settlements to a more dispersed settlement pattern, and this occurred at the time of a large-scale influx of Europeans into the area (Webb 2002:20) (Webb 2002:19). Historic Period (AD 1540 to Present) McDowell County was formed in 1842 from Rutherford and Burke counties and was ' named for Colonel Joseph McDowell, who was an officer during the American 1 8 f 1 1 Revolutionary War (State Library of North Carolina 2007). A previous investigation of the project area was carried out by TRC in February of 2006, and this investigation found no recorded historic structures. This investigation explored the possibility of historic structures or sites within a one-mile radius of the project area, and this identified Brackettown Cemetery, which is near the southwest corner but outside the subdivision boundaries. This cemetery was found to contain African-American and white graves. Brackettown developed on lands owned by the Brackett family and was referred to as a gold mining `Boomtown' during the 19th century. The Brackett family began gold mining in the 1840s using slave labor in the mines. A variety of historic maps were consulted. Only one structure was identified, and it was reportedly located near the town of Brackettown. However, historic maps did reveal the location of a gold mine in the central part of the project area at the eastern part of Lookadoo Mountain. Ernest J. House, along with other investors of the Marion Bullion Company, purchased the on-site mine during the late 19th century. They had intended to run mining operations, but runoff laws discouraged their efforts. The project area lies within the part of McDowell County that is known as the `South Mountain Belt' of gold mining (Olson 2006). Previous Archaeological Investigations A cultural resource literature review for the proposed project area was carried out by TRC in February of 2006 (Olson 2006). This review found that three prehistoric lithic scatters (31 MC 106, 31 MC 108 and 31 MC 109) were identified during surveys that were carried out as part of the Second Broad River Watershed study in 1974, with a second study in 1978. However, these sites are located well outside the project area. An additional site (31MC163) is the Brackettown Cemetery, which is located adjacent to the southwestern boundary, but is outside of the project area. This cemetery was identified through the McDowell County Archaeology Project that was carried out in 1988-1989 (Olson 2006). The majority of the area proposed to be the sites of Lakes 2 and 3 was considered to have moderate to low potential for archaeological sites due to slope. However, Archaic and Woodland period sites have been known to occur in areas where streams are bordered by wetlands and areas of high ground adjacent to the water courses (Avery 2006:14). 9 IV. METHODS I Field Methods Investigations in the field began with a driving and pedestrian tour of the project area to examine terrain and ground cover. .In general, the topography of the area varies according to elevation. Areas near the drainages/streams included wetland-type vegetation such as cane and fern (Lynch 1997; Figure 2). The remainder of the project area (i.e. areas at higher elevations) was found to be covered by mixed woods with mountain laurel, flame azaleas, and rhododendron (Figure 3). Surface visibility was very limited by fallen leaves, ferns and, in several instances, poison ivy. Shovel tests were excavated in areas with less than 15% slope. When these areas were encountered, they occurred either alongside the streams, or on the tops of ridges. A great deal of the project area had slopes greater than 15% (see Figures 4 and 5). Therefore, this limited the area in which shovel tests could be excavated. Shovel tests were excavated at 30-meter intervals along transects 30 meters apart (where space allowed). This interval was reduced to 15 meters when artifacts were encountered. Each shovel test was approximately 30 centimeters in diameter and excavated to sterile subsoil by natural strata. Shovel test depths, soils, and recovered artifacts were recorded on Shovel Test Forms designed by MACTEC. Soil colors and textures were assigned using Munsell color charts. All soils were screened through 0.25 inch (0.6 cm) wire hardware cloth. Recovered artifacts were placed in paper bags marked with project name, shovel test number, transect designation, excavator and date. Color photographs were taken in areas representative of the terrain and ground cover. Lab Methods Only one artifact (a chert flake) was recovered through the survey carried out on the Grandview Peaks project area. This artifact is currently being curated at Knoxville's facility and will be turned over to the state of North Carolina along with the project records. 10 .t? a f 'd! 1 4E ? 4 Yf'l i A w in ?• 04 I, t k 6 J p ? w IV s ? ?s Figure 3. Vegetation on slope along Stream `E'. 11 Figure 2. Vegetation along Stream `E'. t `. J t 12 Figure 4. Slope along Stream in Lake 3. Figure 5. Slope along Stream `E' in Laken. V. RESULTS ' As a result of the survey of the proposed locations of Lakes 2 and 3 within the Grandview Peaks Subdivision, 79 shovel tests were excavated and an additional 12 were recorded, but ' they were not excavated due to slope or disturbance (Appendix A). Only one shovel test (or 1.26 %) produced cultural material. A total of 49 shovel tests were excavated during the investigation of the proposed location of Lake 2 (Figure 6). One positive shovel test ' (Transect 1 Shovel Test 4) was recorded, and this shovel test produced one chert flake that had no diagnostic properties. In accordance with the state of North Carolina, this isolated find was assigned a state site number (31 MC340). The area in which the positive shovel test was located was approximately 100 meters off the road within a valley alongside Stream `E'. The chert flake was recovered from between 0 and 15 centimeters below surface in clayey silt. A total of 30 shovel tests were excavated during the investigation of the proposed location of Lake 3 (Figure 7), but no positive shovel tests were recorded at Lake 3. ' In conclusion, one archaeological site was identified through the Phase I survey on the proposed sites of Lakes 2 and 3 at the Grandview Peaks Subdivision. However, since no additional material was recovered through the delineation of the positive shovel test, no ' further archaeological investigations are recommended. 13 Figure 6. Shovel Tests Associated with Lake 2. 14 1 1 1 1 1 1 1 1 1 I \ \ N-* ti t T1 T10st17 T10st16 T10st? T10st13 T10,i w LEGEND - w sum T6st5 • - D"Point Ar- 0 300' Draffing : RE 6115/07 Source: NCDOT, USGS (Glenwood, NC Topographic Prepared B . LR 6/15107 Quadrangle), map provided by client Chocked B : PG 6/15107 Figure 7. Shovel Tests Associated with Lake 3. 15 VI. RECOMMENDATIONS AND CONCLUSIONS ' Phase I archaeological investigations were conducted between May 21 and 25, 2007, at the proposed locations of Lakes 2 and 3 within the Grandview Peaks Subdivision. The ' proposed project would involve the construction of two lakes within the subdivision for recreation and water supply purposes. A total of 91 shovel tests were excavated, producing only one artifact. The location of this positive shovel test (31MC340) was ' investigated, and no additional artifacts were recovered. Therefore, we do not recommend any further testing at the proposed sites of the lakes. 16 ' VII REFERENCES . Avery, Paul G. 2006 Phase ]Archaeological Survey of The Proposed Location of the Advanced Vehicle Research Center of North Carolina, Northampton County, North ' Carolina, submitted to AVRNC by MACTEC Engineering and Consulting, Inc. ' Lynch, Karen M. 1997 North Carolina Department of Environment, Health and Natural Resources (NCDENR), Common Wetland Plants of North Carolina, Report Number 97-01, August 1997 http://www.esb.enr.state.nc.us/Wetplant/Wetland_Plants.htm accessed on ' 12 June 2007. North Carolina Natural Heritage Program ' 2005 An Inventory of the Significant Natural Areas of McDowell County, North Carolina, Executive Summary, November 2005. www.nenhp.org/Images/McDowellSummary7 14 06.pdf accessed on ' _ _ 05 June 2007. Olson, Heather L. ' 2006 Cultural Resource Literature Review for a 1,860-Acre Site in McDowell County, North Carolina, submitted by TRC to MACTEC Engineering and Consulting, Inc. ' State Library of North Carolina 2007 North Carolina County Development, http://statelibrary.dcr.state.nc.us/NC/CNTYOUT/CNTYMAPS/COLJNT4. HTM#MCDOWELL accessed on 14 June 2007. ' United States Department of Agriculture 2008 Soil Survey of McDowell County, North Carolina, Web Soil Survey 1.1, National Cooperative Soil Survey. Online resource www.soils.usda.gov accessed on 06 June 2007. Webb, Paul A. 2002 Cultural and Historical Resource Investigations of the Ravensford Land Exchange Tract, Great Smoky Mountains National Park, Swain County, North Carolina, Volume I. Submitted by TRC Garrow Associates Inc., Submitted to Eastern Band of Cherokee Indians. 17 1 1 1 1 1 1 1 1 APPENDIX A SHOVEL TEST DATA n F 0 ? o L U ^, `? O U ? U O ? O Z 7 > b "O h O ? O A ? > U U U b xN LLB TJ O cd z U U y, ° z co ? ? ? ? y U ? ? a? U a? y W ? yb N 'v cC cd 5 cC ca cd N b q q J ? ? ? ? ? N ? w z N U U O ? z z z z z z z z z z ^ L C > a y «^ N ?, C ?? U h p C T O C 6 y cd Cf) _ ?C ? 'd' ?D ?' ? ? t\ \O t+ ? N ? ? M M ?O M M \D ' 00 ? ? M V7 ? M M ct 7 V'1 7 V1 M ? c1' '7 V1 d Ct ? ? ? ? 7 7 O: ?i (Y. L1.i Cyr Qi G, . 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O O O O O v'> h O O ? ? h O v-> N M M N N M N N ? N M ? .. O O O M O O O ,?,,, O O O O O O O O N O N d N Q W) :It v7 \O [? 00 01 O - N M 7 v? ?p rlf] N N N N N N N N M Vl IC l- :tt w C.d h C L t'n 7 O .L^ N U N .O U C L C u APPENDIX B STATE SITE FORM PERMANENT SITE NO, ' ARCHAEOLOGICAL SITE FORM III Archaeology Branch, N.C. Division of Archives and History 109 E. Jones St., Raleigh, N.C. 27511 Project site .4 Grandview 1 2. War site # _ 3 Site name _ 4, insfituilor, _ 99 5 Date recorded 22 MAY 07 6. PflRecafder LaDonna A. Rogers ' 7. Grandview Peaks Development Praieci Warne 8 ERICH f s, Court, `-McDowell 10, USGS quad Glenwood 11. UTM cnotainates: ' Zono ,circle) 16 17 18 Northing 13-1-9-13-15 -j,9-j 5 j_ 7 j Easting 14 j?8 j_ 1 1 6 i 9 /, ' 12. Directions to site South on 226 from Marion or 140, continue on 226 through Dysartsville, turn right onto Landis Ln., then turn right onto Joe Branch Road, right into Grandview Peaks, right just inside the subdivision, and then the first un- mamed dirt reed on the the ri ht Just he1hre a small t eqm ' 13. g s r - Describe topography The location is situated in the bottom of a drainage with a nearly level surface that is surrounded by sloping topography. ' 14, Describe vegetation/visibility The vegetation in the area consists of ferns and hardwoods. ' 15. Site descniotiontlimenslons 1 chert flake recovered from a shovel test during Phase I survey. ' 16. Test excavations? yes X nos-___ No. size, placement Once the original positive shovel test was identified along the - transect, an additional 8 shovel tests were excavated around the positive to determine the boundaries of the site. A total rafg.sho '°a taste acnr:nn Affirm by 6hrm 3spre eyrn Ented 1 chert flake was recovered ' 17. List artifacts 18. GUItuf3f components Unknown 19. MACTEC Engineering & Consulting Race artifacts stored 20. Acc. ge ' 21. i ssar n gptenfI Since no additional artifacts were recovered through shovel testing in the immediate area as well as a ong trfae Temammg ranse this sit 22, e recommendations for further work No further work is recommended 23. Describe eite condltlon Since the chert flake was recovered from the first 15 cm of silt and given its proximity to the creek, it is unlikely that it was in situ. 24. National Register aignificance - allg_ non-elig R unknown. -- 25. Ownedtenantilniorman. I Creek Land Com an ATTACH P'HO710COPY OF USES QUAD MAP, SHOWING S/M LOCATION ' ARCHAEOLOOV BRANCH COPY (7st) 4185 AFCOADER COPY (2nd) PERMANENT SITE NO. ARCHAEOLOGICAL SITE FORM III Archaeology Branch, N.C. Division of Archives and History 109 E. Jones St., Raleigh, N.C. 27511 Project site f 3 Site name 3 Date recorded 7. Proiect name _ 2. otrner slta t ?, In53iiutton _ 6. PURecorder 6 ER,CH zt _ - 9, County 10, USG ti quad l l. UTM c6otainates: Zone (circle) 1s 17 18 Nortning 11. 12. Duecttons to site ' 13. Describe typography 14. Describe vegetaiionlvisibility 15. Site descripticnkiimenelonta ' 16. Test (excavations? yes- no____ No size, plecernent ' 17. List artifacts 18. Cultural components 19. Place artifacts stored 20. Acc. Is ' 21. Re6e2ton potemiBt - 22. Recommendations for further work 23. DeSCrlbe alts corttlittnn 24. National Aepister significance - ellg._„,„„ ncn-ebg unknow%_ 25. Owns rttsna ntiintorman ATTACH PH070COPY OF USGS QUAD MAP, SNOWING SITE LOCATION ARCHAEOLOGY BRANCH COPV fist) RECOADe<R COPY (2nd) 4183