HomeMy WebLinkAbout20070168 Ver 1_Staff Comments_20070214Additional Information Request for Grandview Peaks Recreational L...
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Sub'ect: Additional Information Re uest for Grandview Peaks Recreational Lakes 20070168 ~~ W ~ ~~
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From: Kevin Barnett <Kevin.Barnett@ncmail.net>
Date: Wed, 14 Feb 2007 22:32:20 -0500 (EST)
To: ian.mcmillan@ncmail.net
Additional Information Request for Grandview Peaks Recreational Lakes
(20070168)
The Asheville Regional Office has performed a site visit and a review
of the submitted application package. Upon review of the application,
the ARO has determined that the package is incopmplete.
Please include the following in an additional information request to
the applicant:
1. Application Item 19. Project Purpose
You submitted the purpose of the project was" to construct three
recreational lakes."
This purpose lace a need. Recreational lakes, without a need, serve
no purpose.
2. Application Information 2.0 states that the "lakes are to be
constructed to provide water supply points for fire suppression." "The
creation of the proposed impoundments is essential to the success of
the proposed development."
As you Purpose in the application is that the desired impoundments are
recreational, why is the discussion of fire suppression water supply
necessary? Additionally, as you state in Application Item 23 that
"roads and some lots have been completed." At the time of the site
visit, log cabins were either under construction of completed and
occupied. If the impoundments are essential, then how is it possible
to begin development and sell homes without the proposed amenity?
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."
A review of the USGS topographic map for the area indicates that there
is a significant sized impoundment within 3 miles of the Grandview
Peaks Development. You must explain the need for fire suppression
impoundments when the development is within the prescribed area.
4. Application Information 2.2 states that a second need is for
"optional irrigation."
If you have not determined that irrigation is a need, this cannot be
used as reason for causing the proposed impact.
5. Application Information 2.3 states that "few open waters exist in
McDowell County." Application Information 2.3.1 states that "based on
a review of public fishing areas it appears that no other fishing
opportunities exist within the vicinity of the development."
Both Lake Lure and Lake James are within a half hour drive of this
development, providing public boating access, fishing, and swimming.
You must provide a compelling reason as to why these opportunities do
not meet the recreational needs of this development.
6. Application Information 2.3.1 states that fertilization may be
necessary to support the planned fishery.
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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.
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 for this need.
8. Application Information 3.3.2 states that "aquatic species likely
occur within the project area."
A survey should be performed to provide accurate data with respect to
Aquatic Biota in order to determine potential impacts.
9. Application Information 4.1.1 states that "three stream types are
present in the proposed lake location; "F" "B", and "G" type
streams." The previous sentence refers to the stream types as
degraded.
Rosgen B type streams are not considered degraded, and F streams are
transitional streams. Further, and more accurate, stream
classifications must be provided for the systems to be impacted.
10. Application Information 4.2.1 Small Whorled Pogonia - Not Likely
to Adversely Affect
A "walkover" does not constitute a "survey.' A survey of all likely
habitats by qualified personnel must be performed in order for the lead
federal agency to make such a determination.
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 through cost
benefit analysis must be included to support any claim that the impact
is needed for the project to be "economically feasible." The must
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 the
preservation (value of land after development) and the time-value of
money vs. the anticipated financial gain in land values.
12. Application Information 7.2.1 refers to a Erosion and Sediment
Control plan as a Stormwater Management plan.
The two are not interchangeable. You must develop a Stormwater
management plan which would provide for the management of any and all
collected Stormwater for the life of the project which will serve to
protect surface water quality standards.
13. Application Information 8.0 proposes mitigation at a 3:1 ratio
for excellent streams. Table 3 shows proposed mitigation for excellent
streams at a 1:1 ratio.
Table 3 should be modified to reflect the proposed mitigation ratio.
14. Application Information 8.0 additionally states that only streams
in the Catawba Basin will have legal protection.
ti
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As a significant portion of
and in order to comply with
collective impacts which wo
mitigation, ALL streams on
protection.
the property is in the Broad River Basin
15A NCAC 02H .0506 and to protect against
uld subject the applicant to further
the property shall have this legal
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