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HomeMy WebLinkAbout20070168 Ver 1_Staff Comments_20070214Additional Information Request for Grandview Peaks Recreational L... ' n Sub'ect: Additional Information Re uest for Grandview Peaks Recreational Lakes 20070168 ~~ W ~ ~~ J q ( ) 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. 1 of 3 2/1 S/2007 8:10 AM Additional Information Request for Grandview Peaks Recreational L... 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 2 of 3 2/15/2007 8:10 AM Additional Information Request for Grandview Peaks Recreational L... 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 3 of 3 2/15/2007 8;10 AM