20042019 Ver 3_More Info Received_20110808 (3)

WN;t
Wetland and Natural Resource
Consultants, Inc.
August 5, 2011
Ms. Crystal Amschler
Wilmington Regulatory Field Office
US Army Corps of Engineers
69 Darlington Avenue
Wilmington, NC 28403-1343
RE: Anderson Creek South Development, Harnett County, North Carolina
Action ID No. SAW-2006-41244
NC DWQ Project #0 4-2019
Dear Ms. Amschler:
The purpose of this letter is to respond to the issues discussed in our July 8, 2011 meeting at your office.
Alternatives Table:
In the meeting you presented a table that provided assessments and comparisons between the preferred 40
acres alternative and other alternatives. The US Army Corps of Engineers text is in italics; we are
providing the underlined normal text as additional information.
Cost Impacts Ability to Significant benefit to
provide property value
opportunities
for
recreational
benefits
Gol Facilities 4.75 million 12 acres wetland clearing Yes No
Equestrian 1.5 million 0 Yes No
Facilities
Passive 0 0 Yes No
Recreation /
Open Space
Lake Excavated 3.3 million 0 Yes Yes
in High Ground
Expansion of 3.0 million 8 acres open water temporary impacts Yes Yes
Existing Lake 3.5 acres wetland impacts
500 1 (stream impact
Purchase Not Available (Z) Potentially 0 impacts Yes Yes
Existing Lake or
Lake Access
Property
Preferred 40 acre 1.8 million (+ 11.06 acres wetland impact Yes Yes
lake increased cost of 2, 30011(of stream channel impact
mitigation
Construct a 1.26 million {4 Proposed 31.4 acres lake 131 Yes Yes
Smaller Lake that 8.35 acres wetland impacts
doesn't Support 1,838 linear feet of stream impacts
Sailing
No Build 0 Indirect impacts to 10 acres of wetlands and No No
Alternative (" 1,838 plus linear feet of streams
WNR
PO Box 1492
Sparta, NC 28675
1) Significant Benefit to Property Value:
Due to a saturation of like and existing facilities, the developer has determined that supplying golf,
equestrian, and passive recreation facilities does not add significant social or economic benefits to the
value of the property or for that matter the region. As presented previously, there are more than 20 golf
facilities within 20 miles, and an adjacent ],100 acre regional park that provide ample opportunities for
passive recreation and equestrian activities.
The recreational opportunities associated with the lake will provide significant benefit to the public and
property value. The lake is in the public's interest and contributes to needed improvements in the local
economic base.
2 Existing Lake and Lake Access Property
Anderson Creek approached Mr. Norman Keith of the Buffalo Lake's Home Owners Association in May
2011 to inquire about providing lake access to residents of Anderson Creek. The association denied
access and explained that it allows only individual lakefront property owners and their guest's access to
the lake. The same holds true for Carolina Lake and Carolina Trace, both of which charge their own
residents for use of their lakes. Securing access to other existing lakes is not a viable alternative.
No lakes of sufficient size are available for purchase.
3) Smaller Lake that doesn't Support Sailing_
Attached is a plan for a 31.4 acres multi-purpose recreational lake that is sufficiently large enough to
allow for concurrent swimming and wading, non-motorized boating and fishing. The lake is large enough
to provide safe un-crowded recreation for the residents of Anderson Creek and the general public. The
schematic figure shows the locations of proposed swimming areas, docks and fishing piers in relation to
the rest of the lake.
The lake is large enough to allow for sailing and sailing instruction in an informal capacity. While the
lake does not adhere to the dimensional requirements for a sailing school complex it can still be used for
recreational sailing and instruction. Specifically, the leg lengths of the course will not be long enough for
racing but will still have value for instructional purposes.
The 31.4 acres lake provides sufficient area to achieve recreational objectives consistent with existing
public access lakes and recently permitted lakes. Specifically, the proposed lake is proportionally similar
to the approximate 27 acre Tucker Family Lake, located in Benson, Johnston County and the recently
permitted 23 acre Girl Scout Lake located in Oak Springs, Iredell County.
Tucker Lake is located near the City of Benson, the city has a population of approximately 3,600 and
regionally there are approximately and additional 30,000 residents. (US Census data). The Girls Scout
Lake, permitted by the NC Division of Water Quality and the US Army Corps of Engineers, is located on
1200 acres of private property and has been justified to serve 15,000 Girls Scouts in a 150 mile radius of
Charlotte, NC. The proposed lake is not unlike the Girl Scout Lake which was permitted as a multi-use
facility.
At 31.4 acres the proposed lake is approximately 16 % larger than Tucker Lake but is anticipated to serve
a population area that is nearly double the Benson region. The Girl Scout Lake is contemplated to serve
15,000 individuals. In light of these trends, it seems reasonable to allow a lake of 31.4 acres.
2
This proposal represents a significant reduction in the lake surface area and likewise impacts to wetlands.
Lake area
in acres Reduction in lake
surface area from
the contemplated
44 acre lake (2003) Reduction in
area of
wetlands
impacted Uses
October 0 Sailing School Complex
2010 7% 11% • Swimming
• Canoeing
40.3ac • Kayaking
• Fishing
0 Wading
August • Incidental Sailing Instruction
2011 29% 25% • Swimming
• Canoeing
31.4ac • Kayaking
• Fishing
• Wading
A smaller lake that does not support a sailing school complex is feasible, unique, and will generally
satisfy the applicant's needs.
4) Construction Costs:
The cost to construct the 31.4 acre lake is approximately $1,260,000. The design and construction
monitoring is approximately $125,000. The approximate control structure costs are $250,000. The
approximate mitigation costs associated with the lake are $886,000; there are additional fixed mitigation
costs associated with the road construction.
We agree with the mitigation ratios presented in the meeting. Our current mitigation proposal is
consistent our declaration during our meeting and jointly satisfies NC DWQ requirements; it is as
follows:
Wetland Mitigation Amount Ratio EEP Portion On-Site
Lake - Wetland Flooding 7.10 acres l :1 7.10 acres restoration N/A
Dam - Wetland Fill 1.25 acres 21 1.25 acres restoration 12.5 acres preservation
at 10:1 ratio
Roads - Wetland Fill 1.18 acres 21 1.18 acres restoration 11.8 acres preservation
at 10:1 ratio
Total Wetland
Mitigation 9.53 acres
restoration 24.3 acres
reservation
Stream Mitigation Amount Ratio EEP Portion On-Site
Lake - Stream Flooding 1464 linear feet 0.51 732 linear feet N/A
Lake - Dam Fill 374 linear feet 11 374 linear feet 3,740 linear feet of
preservation - 10:1
ratio
Roads - Stream piping 462 linear feet 11 462 linear feet 4,620 linear feet of
preservation - 10:1
ratio
Total Stream 1,568 linear feet 8,360 linear feet
Miti ation restoration reservation
5) No Build Alternative:
The no build alternative is one where the lake would not be constructed.
As discussed in our meeting, approximately 30 acres of the proposed 40 acre lake bed would be
designated to be developed with apartment homes. Using retaining walls, the development of the
potential lake site can occur without impacts to wetlands. Apartment sales are the strongest in today's
market and the land would likely be developed in a short timeframe. The sales of apartments would
generate $6 million dollars which would be used to buy down debt.
The current low impact infrastructure proposed for Anderson Creek in combination with the proposed
preservation of bottomlands will have minimal impact to the environment when compared to alternate
development that could occur on the property. Proposed conservation easements will protect the
remaining streams and wetlands located on the site. If the lake is not constructed it is likely that the
property will be developed with more high density residential development. Likewise, additional road
crossings will be necessary to provide safe circulation in higher density areas. Wetland preservation and
riparian buffers will not be part of an alternate development scheme.
Apartments will add additional run-off to streams, fragment habitat, and have adverse effects on aquatic
resources.
Potential Detrimental Effects to the Aquatic Environment:
Maintaining the proposed lake level will have no effect on the aquatic environment. The submitted study
did not account for existing groundwater and springs within the proposed lake area. These water sources
will be sufficient to maintain a 31.4 acre lake.
Additional Considerations:
Anderson Creek does not construct houses, rather, they provide developable lots for multiple national
builders as well as local builders. Anderson Creek Club represents a construction project of
approximately $1.2 billion invested into the community, $150 million has already been invested
in Anderson Creek Club. The developer alone, Anderson Creek Partners, the applicant, has already
invested approximately $15 million and will ultimately invest approximately $50 million in land and land
development and amenities. The national builders are not attracted to the few lots available in Anderson
Creek North but rather they are interested in the 2,000 single family lots and 900 apartments that can be
constructed in Anderson Creek South. These builders will likely buy a great number of lots within the
development if there is a lake included in project design. It is the experienced opinion of the developer
that the lake will accelerate sales.
Without the lake Anderson Creek is at a significant competitive disadvantage not only against those
regional developments with private lakes, but also against projects elsewhere who are selling to a national
market. Both of their competitors, Carolina Lakes and Carolina Trace, have large exclusive private lakes.
Anderson Creek has residents from 40 states and five foreign countries. In short they have been a
destination and therefore add to economic and community development. They are not selling just to
people who must live in Harnett County but also to people who choose to live in Harnett County because
of Anderson Creek.
The fact that Anderson Creek sells lots not builds houses is important. They are dealing with several large
national homebuilders and those lot buyers are interested in major purchases of lots because of the
amenities. The lake is a crucial amenity for successful sales for Anderson Creek South and also provides
a major amenity for the residents of Anderson Creek North and the general public.
4
We believe that we have in full supplied the information that you requested in your April 8, 2011 letter.
However, we request in advance, a meeting at your office should you find that this submittal is deficient
in any way.
If you have questions or wish to schedule a meeting, please do not hesitate to contact me at 336 / 406-
0906.
Best regards,
jmk#w??
Chris Huysman
Ms. Karen Higgins Congresswoman Renee Ellmers
NC DWQ Wetlands Unit US House of Representative
1650 Mail Service Center 1533 Longworth House Office Building
Raleigh, NC 27699-1650 Washington, DC 20515-3302
Representative David Lewis Mr. Greg Taylor
533 Legislative Office Building BRAC Regional Task Force
300 N. Salisbury Street PO Box 87129
Raleigh, NC 27603-5925 Fort Bragg, NC 28307
Mr. Scott Sauer, County Manager Mr. Joseph Jefferies, Planning Services
102 East Front Street 102 East Front Street
Lillington, NC 27546 Lillington, NC 27546
Senator Kay Hagan Governor James Holshouser
310 New Bern Avenue 100 Market Square
Raleigh, NC 27601 PO Box 1227
Pinehurst, NC 28370
Ms. Jenny Hartsock Ms. Phyllis Owens, Director
310 New Bern Avenue Harnett County Economic Development
Raleigh, NC 27601 PO Box 1270
Lillington, NC 27546
Mr. James Burgin Mr. Donald Belk
Harnett County Commissioner BRAC Regional Task Force
PO Box 1685 PO Box 87129
Angier, NC 27501 Fort Bragg, NC 28307
Mr. Chuck Wakild Dee Freeman
Deputy Director NC DWQ Secretary of DENR
1650 Mail Service Center 1650 Mail Service Center
Raleigh, NC 27699 Raleigh, NC 27699
Mr. J. Keith Crisco
Secretary of Commerce
4301 Mail Service Center
Raleigh, NC 27699
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