20180582 Ver 2_Public Notice Comments_20191007 (4)

Strickland, Bev
From: Mark Simon <[e-mail]>
Sent: Monday, October 07, 2019 4:52 PM
To: SVC_DENR.publiccomments
Subject: [External] Cashiers Canoe Club
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ELA-Wam nc. ov
To all who enjoy the Outstanding Resource Waters of the Chattooga River,
The Cashiers Lake Development as proposed will prove extremely detrimental to the water quality of the Chattooga
River. Excessive runoff associated with the development will only increase sedimentation issues within the
watershed. Development in the headwaters has its impact throughout the entire watershed. Furthermore, mitigation
associated with proposed wetland impact is unable to be fulfilled within the same subbasin.
The Chattooga river was designated Wild and Scenic on May 10, 1974 preserving the resource for the "benefit and
enjoyment of present and future generations."
"It is hereby declared to be the policy of the United States that certain selected rivers of the Nation which, with their
immediate environments, possess outstanding remarkable scenic, recreational, geologic, fish and wildlife, historic,
cultural or other similar values, shall be preserved in free-flowing condition, and that they and their immediate
environments shall be protected for the benefit and enjoyment of present and future generations. The Congress
declares that the established national policy of dams and other construction at appropriate sections of the rivers of the
United States needs to be complemented by a policy that would preserve other selected rivers or sections thereof in
their free-flowine condition to protect the water aualitv of such rivers and to fulfill other vital national conservation
purposes."
(Wild and Scenic Rivers Act, October 2, 1968)
As the development is proposed it will include developing 59.84 acres surrounding Lake Cashiers, dredge/fill 7.13 acres
of wetlands and 4.73 acres of open water with the creation of 18.21 acres of impervious area.
"Sedimentation, or siltation, is the largest single contributor to pollution of the nation's rivers."
(USEPA 1987)
"Physical stream degradation due to sedimentation has become a major concern in the Chattooga River watershed."
"Soils in the watershed are readily erodible once the vegetative cover and forest floor have been removed. Many soils
and the underlying saprolite (weathered plant material) are heavy in micaceous schist, a material that erodes easily
because of its slick flat surfaces and its expandable structure."
Sedimentation in the Chattooga River Watershed
(Van Lear et al. 1995; USEPA 1999)
"Accelerated sedimentation has been identified to be the leading determinant in loss of habitat and reduction in
bedform diversity within the Chattooga River watershed."

Chattooga River Watershed Ecological/Sedimentation Project
(Pruitt, et al. 2001: USEPA 2001)
Cashiers, NC has an average annual rainfall of 80-100 inches and is considered a temperate rainforest. Disturbances in
the headwaters translate downstream.
"Rainfall frequency maps that the Upper Chattooga has more rainfall per unit area than the Lower Chattooga, which
should produce more flow per unit area. The flows estimated at Burrells Ford support more unit flow except for the
summer storm periods. For significant periods each year, the North Fork is producing more than the 23% of the
expected flow in relation to the Chattooga River at Highway 76. Summer non -storm, and dormant season storm and
non -storm data suggest the North Fork at Burrells Ford is producing about 27, 32 and 31 percent of the flow,
respectively."
Upper Chattooga River Visitor Capacity Analysis
U.S. Forest Service
As proposed, the development is required to offset 5.15 acres of wetland impact. There are no mitigation credits
available in the Tugaloo subbasin.
"Due to the unique characteristics of this subbasin, which supports habitats within the Chattooga River the Forest
Service believes it is imperative that compensatory mitigation for the proposed project is carried out within the same
subbasin where impacts would occur."
Janet Mizzi
Field Supervisor
U.S. Fish and Wildlife Service
"The application proposes to acquire mitigation through the North Carolina Division of Mitigation Services, which does
not have a wetland mitigation available in the Savannah River Basin, and would likely use Tulula Bog, a large wetland
complex in Graham County and the Little Tennessee River Basin. North Carolina Wildlife Resources commission strongly
recommends that mitigation be provided on the Highlands -Cashiers plateau, as wetlands in the area have a unique
ecology, driven by geology, climate, and fauna and flora characteristics."
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
North Carolina Wildlife Resources Commission
"The proposal plans to mitigate wetland loss through the NC Division of Mitigation Services. Given the low number of
mountain wetlands, it would be best if those mitigations occurred in the Chattooga River watershed or at least in the
mountains in SW North Carolina."
Michael L. Wilkins
District Ranger
U.S. Forest Service
"Less than % of 1% of our rivers are protected under the National Wild and Scenic Rivers system."
U.S. National Wild and Scenic Rivers System

The stress on this invaluable resource is clearly apparent and there is no lack of literature on this issue.
"For the benefit and enjoyment of present and future generations..."
I implore you... please reconsider the impact of the proposed development and respect the preservation of a resource so
rare that it may be shared for generations to come.
Thank you for your time and consideration.
Mark Simon
Graduate Teaching Assistant
Dept. of Geosciences
2046 Haley Center
Auburn University College of Sciences and Mathematics
Auburn, AL 36849