20080880 Ver 1_More Info Received_20081031

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Wetland and Natural Resource
Consultants, Inc.
October 28, 2008
To: US Army Corps of Engineers
Asheville Regional Field Office
Attn: Mr. Steve Lund
NC Division of Water Quality
401 Wetlands Unit
Attn: Ms. Cyndi Karoly
151 Patton Avenue, Rm. 208 2321 Crabtree Blvd., Suite 250
Asheville, North Carolina 28801 Raleigh, North Carolina 27604
Re: Corps Additional Information Request Response
The Cliffs at High Carolina (+/- 2,780 acres)
Corps Action ID: 200701619 / DWQ Project #: 2008-0880 15
Buncombe County, North Carolina OC T 3 1 2008
Steve and Cyndi:
DENR - WATER QUALRY
WETLANDS AND STORM\NATER BRANCH
The enclosed package is a response to the U.S. Army Corps of Engineers (Corps) letter
dated September 19, 2008 concerning the High Carolina project being developed by the
Cliffs Communities. The written response and attachments address the six bulleted
items in which the Corps summarized comments from their office, from the North
Carolina Wildlife Resources Commission (WRC) office, and from the U.S. Fish and
Wildlife Service (FWS) office. We believe that this response more than adequately
addresses the information the Corps office requested. We also believe that information
contained within the enclosed package will demonstrate that the Cliffs Communities is
proposing measures at High Carolina that are well above and beyond those required by
regulations to protect the natural resources and preserve the environmental value of
the property.
We had previously received an additional information request from the North Carolina
Division of Water Quality (DWQ) on July 15, 2008 and submitted a response on
September 15, 2008. We furnished a copy of this response to the Corps, WRC, and
FWS but are including another copy to these three offices to ensure that it is available
to reference. Please refer to the DWQ package where requested.
Canton Office
PO Box 882
Canton, NC 28716
828-648-8801
828-648-8802 Fax
Please call me at [phone] should you find anything missing, to discuss this
application, or with any questions that you may have.
Best regards:
Jennifer Robertson
Principal
Cc: Mr. Kevin Barnett, NC DWQ
Mr. David McHenry, NC WRC
Mr. Bryan Tompkins, US FWS
Canton Office
PO Box 882
Canton, NC 28716
828-648-8801
828-648-8802 Fax
Executive Summary
This written response and enclosures being submitted on behalf of the Cliffs Communities for the
High Carolina project is in response to the Corps request for additional information. The
information contained in this response demonstrates the commitment that the Cliffs Communities
has to provide design parameters and measures at High Carolina that are well above and beyond
those required by local, state, and federal regulations to protect the natural resources and
preserve the environmental value of the property. The following is a summary of the information
contained:
A. Alternatives Analysis
- The process of locating a parcel suitable for High Carolina involved finding a contiguous
tract that was large enough, minimally developed and was of sufficient altitude to allow
for the required views.
- Through a rigorous process we have clearly demonstrated that all the alternative sites for
High Carolina have been carefully evaluated and exhausted, including consideration of
alternate parcels, not constructing a golf course, and alternate locations for the golf
course on site.
B. Avoidance and Minimization
There are no stream impacts proposed where any of the three trout species occur.
There has been a 50% reduction of golf course impacts from the original preferred
routing (routing #1) of 6,078 linear feet of stream impact to this revised routing (routing
#22 revised) of 3,037 linear feet.
- There has been a 65% reduction of road impacts from the preferred request of 3,370
linear feet to this revised request of 1,170 linear feet.
The revised golf routing plan and road impact plan impacts only 4% of the 99,083 linear
feet of streams at High Carolina.
C. Mitigation
- There has been an increase of 309% of onsite streams to be preserved and an increase
of 394% of upland buffers adjacent to these streams. The majority of the remaining
streams (approximately 89,202 linear feet) onsite not proposed for impact will be
buffered by 30 linear feet on each side which will result in a 60 foot upland undisturbed
corridor.
- There are approximately 5,674 linear feet of additional streams within the golf course
that will be buffered by 75 linear feet on each side which will result in a 150 foot upland
undisturbed corridor.
- These buffers will result in 165.62 acres of protected, forested uplands that will protect
water quality and promote habitat.
- This revised mitigation proposal (based on a 2:1 ratio) provides more than twice the total
linear footage required to mitigate the proposed stream impacts. This mitigation will
include on-site restoration and enhancement, off-site restoration and enhancement, and
on-site preservation.
D. Other Measures
The rate of post development storm water discharge is approximately 25% less than the
predevelopment conditions.
Sediment loading, stream temperature, chemical leaching, and wastewater treatment
have all been addressed to ensure that potential indirect effects to Waters of the US do
not occur.
This response and enclosures are being submitted on behalf of The Cliffs
Communities for their High Carolina project in response to your letter dated
September 19, 2008. Please also refer to the DWQ package included where
requested below.
1. Inadequate alternatives analysis
Asheville has become one of the top destination places in America and
developments within Buncombe County are attracting residents from
across the country. The Cliffs has another community within Buncombe
County, Walnut Cove, which has been extremely successful and known for
its consideration and sensitivity to the environment. The benefit of
developing another community within Buncombe County included the
close proximity of High Carolina to the other Cliffs' communities in order
to share amenities.
The process of developing High Carolina as the next Cliffs Communities
project began with a search of Buncombe County parcels large enough to
incorporate a golf course and residential development. For a parcel to be
considered for development, it must be a large enough tract(s) (2,500 to
5,000 acres) that is minimally developed and at a high altitude in order to
provide a range of property including golf lots, stream lots, open space
lots, and view lots. In order to assemble a property of that size, the Cliffs
must begin with a central initial parcel that can be added to of at least
1,000 acres and add numerous other tracts. As seen in Attachment 1
(Buncombe County Parcel Search Map), there are very few parcels of this
size located in the county, and none of these parcels are available for
purchase.
The map indicates that there are eight privately owned parcels of at least
1,000 acres in size within Buncombe County. Three of these parcels are
part of the Biltmore Estate and are not available for sale. Four of the
parcels are owned by religious organizations and utilized as camps or
retreats; none of these organizations are interested in selling their
property to a development group and one is, in fact, protected through a
conservation easement. The final parcel (an industrial site) is owned by
Chemtronics, a subsidiary of Haliburton, and is currently a superfund site;
because of previous site activities this site was deemed unsuitable for
residential development. These parcels are shown outlined in blue on the
map.
The map also indicates that there are five publicly owned parcels of at
least 1,000 acres in size within Buncombe County. Three of the parcels
(consisting of 19,184.58 acres) are part of the Asheville Water Supply
Watershed and are also not available for sale. Two of the parcels are
owned by the US Government Forest Service and consist of 28,381.8
acres which are not available for purchase. These parcels are shown in
red on the map.
The Cliffs at Walnut Cove and the Cliffs at High Carolina are shown in
orange on the map.
The Cliffs was able to find several adjacent parcels with access to the
Interstate 40 corridor whose owners were willing to sell their properties
and has been able to accumulate a contiguous parcel greater than 1,000
acres in size, but it was a difficult process that eventually lead to the
acquisition of 59 separate parcels to form the 2,800 acre contiguous
parcel. It is doubtful that in today's market conditions that the Cliffs
would be able to find and procure such an assemblage. Since the Cliffs
has already acquired the land, which would not be possible to repeat
within Buncombe County, and since there is a suitable location on site for
a golf course and an off-site golf course would not meet the goals of the
project, the Cliffs and WNR believe that further investigations for
alternative sites for this project should not be required.
Not building a golf course was not an option at High Carolina; a golf
course was an absolute necessity in order to meet the needs of the
project and potential property owners. The golf course at High Carolina
will be the eighth golf course community developed by the Cliffs
Communities. There will be approximately 1,400 homesites at High
Carolina and while not all of the residents of High Carolina will be golfers,
the golf memberships are projected to sell quickly. In the other Cliffs'
Communities, buyers purchase golf front lots even though they do not
play golf.
There are currently 2,520 Cliffs' golf memberships (approximately 70%)
out of a total of 3,535 Cliffs' property owners, and this number is
expected to increase. One of the key elements of Cliffs' membership is
reciprocity with all of the Cliffs' golf courses. Any member of the Cliffs
Communities can utilize the amenities at all of the locations. Such
amenities include golf courses, marinas, restaurants, vineyards, organic
gardens, hiking trails, and fitness facilities.
Although unrelated to High Carolina, several years ago another golf
course architect outside of this project was asked to do a feasibility study
for developing the Swannanoa side of the property to include a golf
course. It was determined that a golf course on the Swannanoa side of
the current project would not be feasible due to the steep slopes. The
small area (approximately 70 acres) on the Swannanoa side with 10 to
20% or slope is not nearly large enough for a 200 acre site required for
golf course construction. There are also five streams and associated
tributaries within the 30 acres that would require impacts.
Within the project boundary, the Cliffs has undergone an extensive site
selection process for the golf course. The golf course architects have
been designing this golf course for over a year and the current routing
plan is the 22nd iteration. WNR has been consulting on this project since
2006 and spent nearly nine months coordinating with the team to prepare
the permit application. There has been an extensive effort put forward by
the Cliffs, engineers, architects, and consultants to create a community at
High Carolina that will not have adverse impact on the natural
environment that exists.
The first two factors analyzed were the topographical slope and the
directional aspect (See Attachment 2 Slope Map and Aspect Map). The
approximate boundary of the proposed golf course is outlined on the
enclosed maps. Locating the largest area of flat topography within the
project boundary was by far the most important factor in golf course
layout and design. As seen on the attached slope map there is only one
area flat enough to support an 18-hole golf course. At this altitude it is
also essential that the aspect of the site be primarily south facing; this is
necessary for adequate sun exposure to ensure healthy grass growth and
to prevent prolonged course freezing in the winter.
The proposed location for the golf course consists of 19 acres of old fields
and residences, 66 acres of historic tree farming, and 15 acres of existing
road network. These previously disturbed areas make up half of the
acreage proposed for the golf course. Locating the golf course in close
proximity to the existing pond in order to have a potential irrigation source
and also to have the opportunity for an open water hazard (Hole #8)
without additional impacts to streams or wetlands was another
consideration. Once the golf course location was chosen the design team
attempted to design an 18-hole layout that would avoid impacting any
resources. Such a strategy was determined not to be feasible given the
existing topography of the site and the geometry of golf course routing.
Initial iterations of the golf course routing plan required not only greater
impacts to streams in terms of linear feet, but also impacted the main
streams where brook trout were present.
In summary the Cliffs believes that they have effectively exhausted the
alternatives analysis for High Carolina which included parcel searches
large enough for the project within Buncombe County, evaluating the
option of not building a golf course at High Carolina, and providing
justification for the proposed location of the golf course within the High
Carolina project parcel.
2. Insuffident measures taken to avoid and minimize impacts to
waters of the U.S. particularly from the proposed golf course
construction but also from the 22 proposed road crossings
There is a reduction of stream impacts at Site 40 on the golf course due
to a 158 linear foot GPS and CAD mapping error: the originally proposed
impact at Site 40 does not exist. Please see attachment 1 of the DWQ
response package for the accurate stream end point. All commenting
agencies expressed general and specific requests for further avoidance
and minimization. Below we have addressed the extensive avoidance and
minimization undertaken by the Cliffs for the High Carolina project. Please
also refer to the DWQ package response for additional information #1.
To better understand the design parameters and constraints we also
recommend reading attachment 4 of the DWQ package first for further
explanation of the golf course design issues, tee design, avoidance and
minimization attempts, and hole by hole justification of impacts. These
explanations provide further discussion on attempts at avoidance,
minimization, and justification of why a given impact cannot be avoided or
minimized.
Within the 2,780 acres of High Carolina there were many layout decisions
to be made including the location of the golf course. Many factors were
looked at in finding a location most suitable for a golf course. Locating
the largest area of flat topography and southerly exposure were integral
in determining the location for the golf course. The existing pond also
was a factor for locating the golf course in order to have a potential
irrigation source and also to have the opportunity for an open water
hazard (Hole #8) without additional impacts to streams or wetlands.
Once the golf course location was chosen the design team attempted to
design an 18-hole layout that would avoid impacting any resources. Such
a strategy was determined not to be feasible given the existing grades of
the site and the geometry of golf course routing. Initial iterations of the
golf course routing plan required not only greater impacts to streams in
terms of linear feet, but also impacted the main streams where brook
trout were present. Even though the Swannanoa side of the property is
available for the golf course, there is no area of flat topography that is
large enough to allow for golf course construction; also this section of the
property is north facing in aspect. The project would not be financially
feasible without the golf course.
The Cliffs at High Carolina project, because of its scope to develop a golf
course and residential community, would not be a viable project without
impacts to streams, wetlands, open water, and the associated trout
buffers. There were 12 bridges originally proposed for road crossings
which will avoid 960 linear feet of stream impacts and will cost
approximately three million dollars. The site plan has been revised to
include an additional 13 bridges which minimizes road impacts by an
additional 960 linear feet for a total avoided and minimized stream
impacts of 2,100 linear feet for road and driveway impacts. This will
result in a total of 25 bridges at an estimated cost of over six million
dollars. Please see the enclosed revised impact and avoidance tables in
Attachment 3 and revised impact map in Attachment 4. Fish and Wildlife
Service has suggested bridging the entire floodplain or utilizing culverts in
the bridge structure to allow high flows. The majority of the stream
crossings are on first and second order small headwater streams; as such
many of the bridges do span the entire floodplain.
The golf course is the focal amenity of this project and cannot be built
without impacts. The design team explored many golf course routings in
order to evaluate how to best minimize impacts on site. The original
submitted golf course routing plan was the 22nd iteration. It was the
result of a significant minimization effort which resulted in only needing to
impact headwaters of the main streams or minor tributaries to the main
streams except in one location, and in an amount that is less than in
previous iterations of routing plans. It was designed to not impact areas
where brook trout exist while still creating the required golf experience to
meet consumers' expectations. Please see attachment 2 of the DWQ
response package. No brook trout were found above the sampling sites
mapped.
The Cliffs has decided to relocate the short game facility to minimize the
original stream impacts proposed for this facility. This will reduce golf
impacts by 652 linear feet. The short game facility will now be located to
the south and southeast of Hole #9. This relocation of the short game
facility will eliminate some prime real estate opportunities near the
clubhouse and cost the development significant lost revenue. The design
team has also eliminated the previous 330 linear feet requested at Hole
#4. Eliminating the stream piping and subsequent fill at Hole #4 will
make tee shots from the back tees more difficult.
Other golf course routing designs required over 5,115 and 6,078 linear
feet of stream piping impacts associated with construction. These other
designs proposed the majority of the stream impacts in the larger reaches
of the streams that flow into the existing pond on the site. Golf course
impacts have now been reduced to 3,037 linear feet which is a reduction
of 50% from the preferred routing option #1. These reductions from the
preferred golf routing plan will impact the playability of the course for
golfers. The following is a table that summarizes the reduction of impacts
from the preferred routing to the revised routing currently proposed.
Golf Course Impacts Linear Feet % Reduction % Reduction % Reduction
Routing Option 1 Preferred 6,078
15.8 1 to 17
Routing Option 17 5,115 33.8 1 to 22
21.4 17 to 22 50 1 to Revised
Routing Option 22 Permit 4,019 40.6 17 to Revised
24.4 22 to Revised
Routing Option 22 Revised 3,037
Several comments have been made regarding shifting golf tees, fairways,
and greens. From a plan view of the impact locations it might appear the
site plan could easily be shifted to avoid surface waters; however,
mountainous topography is a limiting site constraint with any mountain
golf course. In most areas of the golf course 10' to 20' of cut and/or fill is
necessary and in one case 32' of fill is required (as represented by the
brown grading lines on the site plan). In some cases, by impacting
smaller tributaries (e.g. at Hole #1 tee), grades can be adjusted, thereby
avoiding the need to impact the main tributaries. As a part of this
minimization effort, walls have been incorporated where feasible (e.g.
Hole #1 tee); however, in some cases walls were studied (e.g. hole #12)
but determined to be unsafe given the increased human risk such
structures create and were therefore not incorporated. For instance on
Hole #10 near the second landing area, high rock walls could be built to
leave the stream channel open but this would introduce a hazard for golf
carts or golfers of possibly falling over the edge of the wall. Included in
the DWQ response package in attachments 3 and 7 were profiles of the
golf holes where impacts are proposed and cross sections of golf holes 6,
12, and 15 to illustrate the change in grades.
Instead of piping, wherever possible, streams will be incorporated into the
golf course corridor as play-overs. There are seven streams that will
require golfers to play over; these play-overs reduce stream impacts by
3,500 linear feet which will make the play of the golf course more difficult.
The design of the golf course has also incorporated nearly 2,000 linear
feet of walls in order to minimize additional stream and wetland impacts.
Four cart path bridges will be constructed, which will avoid an additional
100 linear feet of stream piping impact and the use of three existing pipes
will prevent 90 linear feet of impact.
There has been a reduction of road impacts of 65.3% from the preferred
request of 3,370 linear feet to the revised option of 1,170 linear feet.
These road impact reductions will require the Cliffs to spend an additional
nearly six million dollars to construct bridges or arched spans. The
following table summarizes the reduction of impacts for roads and
driveways from the preferred request to the current revised proposal.
Road Impacts Linear Feet % Reduction % Reduction
Preferred Option 3,370
36.8 Preferred to Permit
Permit Option 2,130 65.3 Preferred to Revised
45.1 Permit to Revised
Revised Option 1,170
In summary there has been a reduction of golf course impacts from the
preferred routing of 6,078 linear feet of stream impact to the revised
compromised routing of 3,037 linear feet which is a 50% reduction. This
reduction of impacts will make the course much more difficult to play for
golfers. This reduction includes forcing golfers to play yet another forced
carry. There has been a reduction of road impacts of 65.3% from the
preferred request of 3,370 linear feet to the revised option of 1,170 linear
feet. The revised golf routing plan and road impact plan proposes impacts
to 4% of the 99,083 linear feet of streams at High Carolina.
3, Establishment of buffers of sufficient width and composition
(forested) to protect brook trout populations and other aquatic habitat
on remaining stream channels
All of the remaining streams on site will be preserved (94,876 linear feet;
over 18 miles). A minimum of a 30' buffer will be preserved on all
remaining streams beyond the streams noted in this revised package
proposed for impacts which include approximately 89,202 linear feet of
streams. These 30' buffers result in 154.32 acres of preserved buffers. It
has been determined that there are areas within the golf course where
wider buffers can be preserved. Please see the enclosed map in
Attachment 4 (Revised Buffer Map). Approximately 5,674 linear feet of
streams will have wider than 30' buffers. These buffers result in 11.3
acres of additional upland buffer.
It is the Cliffs' intention to preserve at least 165.62 acres of stream
buffers. The linear footage of stream preservation has increased from the
original proposal by 309% and the upland buffer acreage that will help to
protect the water quality of these preserved streams has increased by
over 394%. These forested buffers will help to ensure that the existing
brook trout population is sustained as well as the other aquatic habitat on
site. Please see the restrictive covenant language that was included in
attachment 5 of the DWQ package for the stream preservation and buffer
area protective language that the Cliffs will be recording.
Even though the Buncombe County storm water ordinance requires a 30'
buffer along streams it does not have to be forested. Under Buncombe
County's requirements, this buffer could be grassed or improved in any
manner as long as there are no storm water devices or impervious
surfaces within the buffer. The Cliffs is going above and beyond by
preserving these buffers as forested areas. The additional buffers within
the golf course will also be forested.
There are areas within the golf course that will have a much wider
vegetated buffer than the proposed 75'. These wider buffers occur along
3,682 linear feet of streams within the golf course. These additional
buffers will extend the 75' buffers by an additional range of 140' to 515'
and will remain forested.
4. Storm water management concerns
The Cliffs has received storm water approval from the Buncombe County
Storm Water Management program for the golf course and will continue
to pursue additional phases. The Cliffs will comply with all the
requirements of Buncombe County Storm Water Ordinance. The program
was established to control the adverse impacts due to storm water runoff
associated with new development. These requirements include 1 day
drawdown time, pre-development discharge rate, protecting receiving
water trout stream temperature, and no impervious surface or storm
water controls located within 30 feet of any surface water. The Cliffs will
utilize various methods to minimize storm water flows from impervious
areas; they will install permanent measures to control the rate of runoff to
that which existed prior to development for the 1 year 24 hour storm
event.
All individual lots will require the installation and use of cisterns or rain
gardens to control storm water on each individual lot. Due to the Cliffs
approach of developing the property as a low impact development the
impervious surfaces will be approximately 8%; far less than the typical
24%. The post development rate of storm water discharge will be
approximately 25% less than compared to the existing pre-development
conditions. Some areas will utilize detention devices to capture storm
water from common buildings and parking areas. Also all multi-family
units will incorporate cisterns to gather storm water as well.
5. Inadequate consideration of indirect effects on waters of the U.S.
particularly on the existing brook trout population
1. Water Balance - The domestic water for all the homes and amenities at
High Carolina will be provided by the City of Asheville from its municipal
water supply. At full build out, the total flow to the development from
Asheville Water is projected to be approximately 600,000 gallons per day,
all of which will be a net addition to the water balance on the property.
The Cliffs has elected to require that all residences construct and maintain
water conservation/detention devices on-site which will recharge the
groundwater and protect the streams. The homeowner may select from
several options which include cisterns, rain gardens, etc. Currently, High
Carolina is the only development in Buncombe County which has
implemented this conservation practice.
In addition, the irrigation water utilized for the golf course and
surrounding landscape will remain on-site and recharge the groundwater.
This water will come from three sources. The first source will be the
effluent (discharge) from the on-site wastewater treatment plant which
will be treated to reuse standards which is the highest treatment standard
in the state. A computerized irrigation system will be used to regulate a
consistent watering schedule, using less water more efficiently. A drought
will not affect the wastewater treatment plant's output. The second
source will be the rainwater from the amenities which will be collected and
stored in cisterns. This water will be blended with the wastewater
treatment plant effluent and used for irrigation. The third source of
irrigation water for the golf course will be the existing on-site pond. The
Cliffs Communities will maintain base flow in the stream below the pond.
Sediment loading, stream temperature, chemical leaching, and
wastewater treatment have all been addressed below to ensure that
potential indirect effects to Waters of the US do not occur. The Cliffs
working hand in hand with Clemson University's Turf Grass Science
Section of its Department of Horticulture to finalize state-of-the-art
procedures and standards for the construction and operation of the golf
course.
2. Trout Buffers - We propose the following conditions at each of the
proposed trout buffer disturbance locations to prevent indirect effects of
Waters of the US:
1. An erosion and sedimentation plan for the portion of the access roads
within the trout buffers shall be submitted and approved by NC DENR's
Land Quality office before land disturbing activities begin.
2. During the installation of the in-stream piping, the stream flow shall be
diverted around the work area as per the approved details.
3. The pipe installation schedule and all details shown in this package will
be complied with and strictly followed except where weather may
require a revision to the schedule. If revisions are needed we will
inform DLR- Central Office and Asheville Regional Office before the
revisions are implemented.
4. The National Weather Service forecast will be monitored three days in
advance of any land disturbing activity. Land disturbing activity will
not begin if within the next 24 hours a > 50% chance of > 1/4" of
precipitation is forecasted.
5. All disturbed areas shall be stabilized with an adequate temporary
ground cover at the end of each workday. An adequate temporary
groundcover may consist of sufficient mulch, which is adequately
tacked on areas that will receive additional fill within 30 calendar days.
6. All materials excavated during any work within the buffer, except for
materials to be used as backfill during pipe installation for that day,
will be deposited at least 25 feet from the top of the stream bank,
outside the trout buffer zones, and stabilized with an adequate
temporary ground-cover at the end of each workday. Areas for
disposal of excavated materials will be identified, and subsequently
submitted to and approved by this DLR-Central Office before any land
disturbing activity begins.
7. A person qualified in erosion and sedimentation control shall be on site
for all land disturbing activities within the trout water buffer zones
during construction of the golf course.
8. Areas for the installation of settling basins for seepage will be
identified, and a detail developed for such basins. Before the
installation of any pipes begins, the proposed areas and the detail will
be submitted and approved by DLR-Central Office.
9. All materials required for the installation of pipe, construction of
sediment control measures, and the installation of erosion control
measures for each drainage system will be onsite before land
disturbing activity begins for that run of pipe.
10.The approved erosion and sedimentation control plan for golf course
construction will have adequately sized control measures.
11. All erosion and sedimentation control measures will be kept out of the
trout buffer zones unless otherwise approved. No discharge points will
be allowed within the trout buffer zones.
12. All work within the trout buffer zones will be prohibited during the
trout spawning season.
13. All temporary sediment control measures will be removed within two
months of project completion.
14.The DLR-Central Office and the Asheville Regional Office will be
notified 24 hours in advance before beginning the project.
15.All of the proposed disturbance areas have been marked in the field
with orange construction fencing. Additionally, the trout buffers have
been flagged along reaches where the golf course grading construction
is within close proximity to the buffer.
High Carolina is located in Buncombe County, which has delegated
authority for Sediment and Erosion Control. High Carolina will submit an
Erosion Control Plan to Buncombe County for approval, and will not begin
land disturbing activities on site until they receive approval.
The plan will include specifications for:
1) A buffer zone adjacent to all natural watercourses, including an
undisturbed 25' buffer along trout waters.
2) An angle of cut-and fill slopes sufficient for proper stabilization.
3) Measures to prevent off site sedimentation.
4) Provisions for continuing maintenance of all structures as needed.
5) Temporary sediment and erosion control devices will be constructed in
a manner that disperses water through the trout buffer.
High Carolina will utilize necessary measures to prevent sedimentation in
all surface waters on site, trout streams in particular. The Cliffs
understand the purpose of the law, which requires installation and
maintenance of sufficient erosion control practices to retain sediment
within the boundaries of the site. They also understand that disturbed
surfaces should be non-erosive and stable within 15 working days or 90
calendar days after completion of the activity, whichever period is shorter.
There is an existing dam below the proposed trout buffer impacts that
separate the lower reach of Rocky Fork from the headwaters.
In order to protect the trout buffers the Cliffs proposes the following
stringent sequence for tree removal within trout buffers.
Construction Sequence: Tree removal within Trout Buffers
1. Receive Trout Buffer Variance Approval.
2. Limits of Trout Buffer within disturbance areas and in close proximity
to graded areas have been marked in the field; limits of disturbance
and/or tree removal areas have been marked with orange construction
fencing.
3. It is recommended that general fairway clearing (outside the trout
buffer) occur separately to encourage strict adherence to specific trout
buffer clearing conditions and to create an open work area outside the
buffer.
4. Any trees within the buffer that are supposed to be removed or topped
will be flagged.
5. Canopy trees & under story vegetation that is not flagged will remain
intact at all locations unless otherwise specified.
6. Approval from DLR with consultation form WRC will be obtained before
any trees are removed.
7. Tree removal will not begin until the adjacent area is stabilized.
8. Tree removal shall be accomplished with equipment that will minimize
the disturbance of stabilized areas on the site.
9. Trees will be cut above the ground and the stump and root mass will
be left in place.
10.Trees will be felled and removed from the buffer using equipment, to
minimize ground disturbance.
11. Any under story vegetation that has to be removed will be removed by
hand only.
12. General care will be taken not to cause any bed or bank disturbance to
the stream channel.
13. Personnel and equipment will be kept out of the water. Equipment will
only cross creeks at designated areas.
3. Sediment Loading - All erosion control and storm water will be
permitted through Buncombe County and maintained to the required
standards. Although during the construction of the golf course the ground
will initially be disturbed (as required by the grading permits), the Cliffs
will be installing silt fences and a series of sediment basins to control the
runoff and sediment. Once the golf course is established, the trees,
shrubs and sod will hold the soil in place, and the soil will no longer be
disturbed. In addition, a minimum of a thirty foot buffer will be kept and
maintained along all streams in order to filter the runoff prior to entering
the stream and to minimize the potential for erosion. Within this buffer,
no storm water devices are allowed and, therefore, none are proposed.
4. Chemical Leaching - As noted in recent research on golf courses in
North Carolina completed by Dr. Tom Rufty of NCSU, the establishment
and fertilization of a golf course should not increase the chemicals
leaching into surrounding waters. All fertilizers and pesticides to be
utilized will be licensed by the EPA for use on golf courses and applied by
state licensed applicators utilizing dedicated equipment designed
specifically for the appropriate application; a list is available upon request.
An integrated pest management plan will be prepared and managed by
the golf course superintendent. The plan will include soil and tissue
sampling as well as the use of a licensed plant pathologist. All golf course
equipment will be washed down at the end of each day using a golf
course wash station. The grass clippings will be removed and collected;
the wash water will be channeled through a filtered wash system utilizing
a sand filter.
University and government studies indicate that properly applied
pesticides and fertilizers do not leach into groundwater in any appreciable
amounts. Modern turf -grass management practices greatly reduce the
potential for leaching or runoff into water supplies. Pesticides and
fertilizers are used only on certain portions of the golf course such as tees,
fairways, and greens. The remainder of the course will consist of drought
tolerant, naturalized areas that reduce the need for both water and turf
care products.
5. Water Temperature - The North Carolina Division of Land Resources'
Land Quality Section regulations require a minimum of a twenty-five foot
buffer along any stream classified as "Trout Waters". Any piping or hand-
clearing within trout buffers requires a variance through the Land Quality
Section. Low growing shrubs such as rhododendron, mountain laurel, and
dog hobble will be preserved or planted at play-overs. This vegetation is
native to North Carolina and provides shade and cover for aquatic
organisms and keeps the temperature of the water cool.
Most of the trout stream buffers consist of canopy vegetation and dense
under story. The canopy vegetation includes ash, hickory, oak, red
maple, tulip poplar, hemlock, and buckeye. The under story vegetation
includes rhododendron, mountain laurel, and doghobble. The mature
under story vegetation will provide shade to the stream in the hand
clearing disturbance areas. The existing thickness of this under story
layer provides the majority of shade for the trout streams. The seeps
within the trout buffer disturbance areas where we have proposed piping
the streams will be shaded by the pipe.
The construction of High Carolina should actually /owerthe water
temperatures in the stream below the dam because the Cliffs will be
repairing the existing on-site dam and bringing it into compliance with the
North Carolina Dam Safety requirements by adding a coldwater release.
The water temperatures of the streams above the dam within the
proposed golf course will be lowered as well because some of the
headwaters will be piped and will not be exposed to sunlight.
6. Wasterwater Treatment - An onsite wastewater treatment plant is
being designed by Brooks Engineering Associates to meet current N.C.
rules and regulations for the DENR On-site Water Protection Section. It
will be designed to treat the wastewater for all facilities located in the
High Carolina development. Wastewater treatment will consist of a
surface drip system that will not require any land disturbance within the
drip fields for installation or operation. This type of wastewater system
puts nutrients into the ground and reduces the need to chemical
application on the golf course when it is used for irrigation.
In summary the establishment and operation of High Carolina should not
negatively impact water quality of the area. The Cliffs has an unblemished
track record of no incidents or violations with any of the regulatory agencies
over the construction and operation of its six completed golf courses and
the one currently under construction. Furthermore, at The Cliffs at Keowee
Vineyards, the eight holes that are located immediately adjacent to the
lake's shoreline which is a water reservoir for several upstate counties and
municipalities have been continually monitored (even during construction)
without issue.
6. Lack ofsuffi ent stream and wet/and mitigation to offset
unavoidable impacts
The Cliffs will agree to provide 2:1 mitigation for all of the impacts to the
streams. The revised proposed mitigation for this project will include on-
site restoration and enhancement, on-site preservation, and off-site
purchased credits. Please see a revised mitigation table in Attachment 5.
Even though the Cliffs already has an acceptance letter from EEP for all of
the proposed stream piping impacts, they have contracted with
Restoration Systems, LLC of Raleigh, NC to perform stream restoration of
Crab and Shoal creeks at the Shoal Falls Farm site in Henderson County.
This option was selected because of the shift for preference toward using
private mitigation firms. At the Shoal Falls Farm, site agricultural practices
which include the removal of riparian vegetation, the relocation of
streams, the dredging of streams, and the straightening of streams have
resulted in degraded site conditions including water quality, flood storage,
trout habitat, and stream characteristics.
The Shoal Falls Farm project is deemed highly desirable because it
consists of classified "Trout waters" supporting multiple species of trout
and "High Quality Waters", and it drains directly to critical habitat for the
federally endangered Appalachian elktoe (Aiasmidonta raveneiiana) in the
Little River. The streams proposed for restoration at Shoal Falls Farm
have been used for livestock grading and hay production. There will be
30' buffers established along the restored streams. One of the goals of
this mitigation project is to improve trout habitat, migration, and spawning
in the areas where trout (including Brook Trout) were found during
surveys conducted in May 2008. The streams proposed for impact at High
Carolina are first and second order streams while the streams proposed
for restoration at Shoal Falls Farm are third and fourth order streams.
Please see attachment 6 in the DWQ package for additional revised
information concerning Shoal Falls Farm.
Please see the response to #3 above for details about the streams that
will be preserved on site.
Attachment 1
Buncombe County Parcel Search Map
(at least 1,000 acres)
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Attachment 2
Slope Analysis Map
Aspect Analysis Map
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157.51 - 202.5 S
202.51 - 247.5 SW
247.51 - 292.5 W
292.51 - 337.5 NW SR
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Aspect within Project Area
Percent Slope Face
014.226
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Attachment 3
Revised Impact Table
Revised Avoidance and Minimization Table
High Carolina Impact Table
Road Impacts
Channel Impacts
Site # Length (ft.)
5 80
8 80
12b 20
13 80
13b 40
16 80
17 50
19 80
20 80
20b 20
21 80
21b 20
22 20
23 80
23b 80
24 80
25 80
25b 40
25c 80
1170
Wetland Impacts
Site # Size (ac.)
16a 0.135
0.135
Golf Impacts
Channel Impacts
Site # Length (ft.)
26 275
27 211
28 375
29 234
30 171
35 122
36 437
37 1054
39 0
40 158
3037
Wetland Impacts
Site # Size ac.
31 0.008
32 0.014
33 0.027
34 0.024
38 0.011
0.084
Open Water Impacts
-Site # Size (ac.)
41 0.03
0.03
Total Impacts
Wetland Impacts (ac.): 0.219
Channel Impacts (ft.): 4207
Open-Water Impacts (ac.): 0.03
High Carolina Avoidance & Minimization Table
Avoid & Minimize
Road Impacts
Channel Impacts
Site # Length ft.
4 80
5b 60
6 80
6b 60
7 40
9 80
10 80
11 80
12 80
14 80
14b 80
15 80
18 80
42 80
43 80
44 80
45 80
46 80
47 80
48 80
49 80
50 80
51 80
52 80
53 80
1920
Golf Course Routing Plans
Channel Impacts
Routing Option Length ft.
1 1096
2 2059
Lot Impacts
Channel Impacts
Site # Length ft.
I 30
II 30
III 30
IV 30
V 30
VI 30
180
Golf Impacts
Channel Impacts
Site # Length ft.
29 652
39 330
54 30
55 30
56 30
1072
Golf Course Cart Path Crossings
Channel Impacts
Hole # Length (ft.)
1 40
6 20
9 20
11 20
100
Attachment 4
Revised Impact Map
Revised Buffer Map
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Development
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I High Carolina Impact Map I Overview I Scale: 1"=2500' 1
HIGH CAROLINA
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4
4

High Carolina Impact Map I Sheet 1 1 Scale: 1"=500 1

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High Carolina Impact Map Sheet5 Scale: 1°=5009
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High Carolina Impact Map Sheet6 Scale: 1"=500' 1
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High Carolina Impact Map Sheet8 Scale: 1"=500' 1
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High Carolina Impact Map I Sheet 10 1 Scale: 1"=500

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High Carolina Impact Map Sheet 11 Scale: 1"=500

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I High Carolina Impact Map I Sheet 12 1 Scale: 1"=500' 1
HIGH CAROLINA
The Cliffs Commuities
Residential Development and Golf Course
Buncombe County, North Carolina
0 1000' 2000' 4000' 6000'
Itants
5
1"=2000' WNR : 2-14-08
Preservation Map
Mme:
The Cliffs Communities - High Carolina
Buncombe County, North Carolina
The Cliffs Communities 7WCOTC-C-1005/10091
se
High Carolina Preservation Buffers
Length with 30' buffer both sides 86,103 I.f.
Length with 30' buffer one side 3,099 I.f.
Total Area of 30' buffer 154.32 acres
Length with 75' buffer both sides 1,334 I.f.
Length with 75' buffer on side 4,340 I.f.
Total area of 75' buffer 11.30 acres
Total area of preservation buffers 165.62 acres
30 ft. Preservation Buffer
75 ft. Preservation Buffer
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High Carolina Preservation Map Overview Scale: 1"=2500' 1
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High Carolina Preservation Map I Sheet 1 1 Scale: 1"=500 1

z
0
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High Carolina Preservation Map I Sheet2 1 Scale: 1"=500 1

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I High Carolina Preservation Map I Sheet 3 1 Scale: 1"=500 1
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High Carolina Preservation Map I Sheet4 1 Scale: 1"=500 1
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, -S
?\
High Carolina Preservation Map I Sheet5 1 Scale: 1"=500 1
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High Carolina Preservation Map I Sheet6 1 Scale- 1"=500 1
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High Carolina Preservation Map I Sheet? 1 Scale: 1"=500 1

i High Carolina Preservation Map I Sheet8 1 Scale: 1"=500 1
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High Carolina Preservation Map I Sheet9 I Scale: 1"=500

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High Carolina Preservation Map I Sheet 10 1 Scale: 1"=500

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a
High Carolina Preservation Map Sheet 12 Scale: 1"=500-
Attachment 5
Revised Mitigation Table
High Carolina Mitigation Overview
Mitigation Needed for Stream Im acts

Type of Impact
Amount
(l.f.) Mitigation Ratio
(Based on Stream
Quality) Multiplier
(Based on
Impact)
Final
Ratio
Mitigation
Requirement (SMU)
Culverts Roads 1170 2:1 Good uali 1 For Fill 2:1 2,340
Culverts Gol 3037 2:1 Good uali 1 For Fill 2:1 6,074
Total 8,414

Mitigation Needed for We tland Im acts

Type of Impact
Amount
(ac.) Mitigation Ratio
(Based on Stream
Quality) Multiplier
(Based on
Impact)
Final
Ratio
Mitigation
Requirement (SMU)
Culverts Wetlands 0.219 2:1 Good uali 1 For Fill 2:1 0.438
Total 0.438

Mitigation Proposal for Stream Im acts

Type of Mitigation

Method

Amount Proposed l.f. Multiplier
(Based on
Activity)

SMU
Restoration on-site 521 1 521
Restoration Shoal Falls off-site 3,506 1 3,506
Enhancement Level I on-site 30 1.5 20
Enhancement Level II on-site 403 2.5 160
Preservation 75' buffer on-site 5,674 4 1418.5
Preservation 30' buffer on-site 90,240 8 11,280
Total
Total 16,905.5 linear feet

Mitigation Proposal for Wetland Imp acts

Type of Mitigation

Method

Amount Proposed ac. Multiplier
(Based on
Activity)

SMU
Restoration on-site 0.014 1 0.014
Restoration Shoal Falls off-site 0.424 1 0.424
Total 0.438
I __ I Total 0.438 acres
___ f