20180612 Ver 2_Individual_20200110

CLearWaLer
C1earWater Environmental Consultants, Inc.
January 7, 2020 www.cwenv.com
Mr. David Brown
US Army Corps of Engineers
Asheville Regional Office
151 Patton Avenue, Room 208
Asheville, NC 28803
Mr. Mac Haupt
N.C. Division of Water Quality
401 Wetlands Certification Unit
1650 Mail Service Center
Raleigh, North Carolina 27699
a 61 �6W-a v,)-
RE: Western Carolina University 2014 Master Plan Improvements
USACE Action ID 2015-00263
NC DWQ Project No. 20180612
Jackson County, NC
Dear Mr. Brown and Mr. Haupt,
\9c
Please reference the "Department of the Army Permit" dated September 21, 2018 sent by the US
Army Corps of Engineers (Corps) and the 401 Certification dated January 9, 2019 issued by the
N.C. Division of Water Resources in response to the permit application submitted by C1earWater
Environmental Consultants, Inc. (CEC), on behalf of Western Carolina University (WCU). These
permits authorized impacts associated with student parking and intramural athletic field at WCU
in Cullowhee, North Carolina (Figures 14). The authorizations approved 500 linear feet of
stream impacts and 0.383 acres of wetland impacts. The authorizations are attached for review
(Attachment A). The applicant respectfully requests that these authorizations be modified to
reflect the changes illustrated on the Revised bnpact Map (Figure 5 and 5A) and discussed below.
This permit modification request includes additional wetland impacts totaling 0.35 acres and open
water impacts totaling 0.47 acres. This request is necessary because the impacts limits based on
the Campus Master Plan are greater than was originally determined in preliminary planning.
There are no additional modification requests for impacts to streams.
Authorized Action
The Authorized Action as permitted in 2018-19 included improvements to meet needs identified
in WCU's original permit application dated May 1, 2018, which include the construction of a
parking lot and improvements to the intramural fields: The specific improvements included:
• Construction of a surface parking lot capable of providing 441 parking spots adjacent to
Central Drive.
• Improving the usability of intramural sports fields by constructing an even grade surface
conducive for maintaining turfgrass.
32 Clayton Street
Asheville, NC 28801
828-698-9800 Tel

Western Carolina University Master Plan Improvements
Permit Modification request
December 12, 2019
Page 2 of 6
Impacts of the Proposed Modification
The total impacts (original and modifications) to Waters of the US for the WCU Master Plan
Improvements will require the placement of fill materials into a total of 500 linear feet of stream'
(perennial) channel, a total of 0.733 acres of wetlands and 0.47 acres of open waters/ponds. (See
Figure 5 and 5A dated December 11, 2019)
The total impacts of the WCU Master Plan Improvements (Original and Modification) have been
tabulated and are shown in Figure 5.
• 0.733 acres of wetlands
0.07 acres linear ditch, with emergent vegetation wetland
0.293 acres forested wetland
0.37 acres floodplain depressional herbaceous wetlands
• 500 linear feet of perennial stream
• 0.47 acres of open water/ponds
Permit Modification Impacts
It is important to note that there has been no change to the overall project purpose of the WCU
Master Plan Improvements which reads: "The project purpose is to enact several development
recommendations provided within the 2014 Campus Master Plan. These recommendations
include meeting a growing demand for parking and maximizing the utility of existing open spaces
on campus. " Impacts associated with the intramural fields are directly related to the originally
permitted project.
The Western Carolina Campus Recreation and Wellness program has indicated that the current
primary spaces utilized for Intramural and Club Sport program need to be improved for safety and
functionality and expanded to meet demand. The WCU Norton fields will be the site of five
additional athletic fields, including one football field, one soccer field, two multipurpose athletic
fields, and a hammerthrow field. The proposed improvements will also include expansion of parking
facilities with the addition of a parking lot on the north end of the intramural field site, capable of
accommodating approximately 50 vehicles. The purpose of this project is to improve the usability of
intramural sports fields by constructing an even grade surface conducive for maintaining
turfgrass. In addition, this project provides additional parking, which is a demonstrated need
discussed in the original permit request.
This project will result in additional impacts to 0.35 acres of jurisdictional wetlands and 0.47 acres of
impacts to jurisdictional open waters. Impacts to 0.3 additional acres of wetlands will be necessary
for the construction of additional athletic fields, including a soccer field and a hammer throw field.
Impacts to 0.05 additional acres of wetlands will,be necessary for the expansion of the existing
parking lot for approximately 50 new parking spaces to support the increased attendance to the new
fields.

Western Carolina University Master Plan Improvements
Permit Modification request
December 12, 2019
Page 3 of 6
Alternatives
WCU investigated alternatives in preparation for this permit modification request. Proposed
alternatives must achieve the project purpose of "Improving the usability of intramural sports fields
by constructing an even grade surface conducive for maintaining turfgrass." The following
criteria for selecting alternatives were developed:
Criteria 1: Proximity to Campus: The preferred alternative will be on the WCU Campus or
immediately adjacent to the WCU campus within a reasonable walking distance or accessible by
campus public transportation
Criteria 2: Flat or low gradient acreage of approximately 10 AC or greater contiguous area: The
preferred alternative will have sufficient lowgradient acreage to accommodate five additional
athletic fields..
Alternative 1: Alternate location for expanded use on campus
In this alternative, the expansion of intramural and club sports would be accomplished by
holding practices in an alternative location on campus. Current facilities include the Camp
Lab Fields and the Athletic Practice Football field (CRW Fields 1-3), the Athletic Football
Stadium (Bob Waters Field), the Athletic practice soccer field (Shrader Field), and
Catamount Athletic Complex. (Fig 1). The Athletic football stadium (Bob Waters Field) and
the Athletic Practice football field are used for Club Ultimate Frisbee and Men's and
Women's Soccer when not utilized by the Athletic football team. Club Sports utilizes the
Athletic practice soccer field (Schrader Field) when hosting club soccer matches and the
football stadium (Bob Waters Field) when hosting club Ultimate Frisbee matches. The
only flat open spaces on campus large enough to accommodate additional athletic fields are in
the vicinity of the Camp Lab fields and Football Practice Field (CRW Fields 1-3) and the
Norton fields (Figure 6).
The Camp Lab. Fields have two designated fields, which are used for Intramural games (Flag
Football League, Ultimate Frisbee League, Outdoor Soccer league, Punt, Pass, Kick, Kickball
Tournament, Softball League, 4 on 4 Flag Football Toumament/League) Monday -Thursday
from 4:30pm — IIpm, and occasionally Sundays. In addition, Club Sports (Men's and
Women's Rugby, Men's and Women's Soccer, Men's and Women's Lacrosse, Ultimate
Frisbee, Baseball) utilize the same space Monday- Thursday 5-10 pm and Friday 5-7 pm.
The remaining times Monday -Thursday from 8am-4:30pm and Saturday -Sunday 8am-8pm
are available for unscheduled informal recreation but no lighting is available during this time.
There is little room for modification of the existing field schedule to accommodate increasing
utilization of the facilities. Natural grasses need to rest in order to prevent ongoing wear and
tear and are not available during inclement weather. Significant time and resources are spent
into the weekly painting and maintenance of the existing fields. The existing schedule on the
Camp Fields could not be expanded, because the schedule does not allow for resting the
natural turf grass and for ongoing maintenance. The CRW Fields 1-3 are already utilized for
intramural practices and could be improved. However, if the fields were reconfigured to
accommodate additional play area, the space would still be insufficient to accommodate the
proposed scale of improvements, which is five proposed additional athletic fields dedicated
for Intramural and Club Sports.

Western Carolina University Master Plan Improvements
Permit Modification request
December 12, 2019
Page 4 of 6
Alternative 1 would achieve the project purpose of "improving the intramural sports fields"
There would be no impacts to Waters of The US under this alternative. Alternative 1 meets
the Criteria 1 of proximity to campus. Alternative 1 does not meet the Criteria 2 of at least 10
acres for additional athletic field space. Therefore, Alternative 1 has been eliminated from
consideration.
Alternative 2: O site expansion of intramural sports practice at existing facilities
This alternative consists of siting the intramural sports practices in an alternate location off
campus, at the Jackson County. Recreation Complex, located approximately 2 miles south of
the university main campus entrance. This would require transportation of students to the
offsite location either through personal transportation means, public transportation, or by the
university transport system. The Cullowhee recreation complex provides recreational services
to the community and is already extensively utilized by non -university participants. For
example, youth flag football league utilizes the fields Tuesday and Thursday evenings from
the months of May and June. Physical education classes are offered for homeschool students
ages five through fifteen, with weekly classes offered in the spring and fall. Soccer programs
are offered for children ages four through fourteen in both the spring and fall. These along
with other community programming happening within the indoor recreational complex
impact the availability of the fields for use by university.
There would be no impacts to Waters of The US under this alternative. Alternative 2 meets
the Criteria 1 of proximity to campus. Alternative 2 does not meet the Criteria 2 of at least 10
acres for additional athletic field space. Therefore, Alternative 2 hasbeen eliminated from
consideration.
Alternative 3: O site expansion of intramural sports practice at undeveloped property
This alternative consists of siting the intramural sports practices at an alternate location off
campus, that has not yet been developed for athletic use.
Alternative 3a is parcel # 7559-27-8152 consisting of 11.8 acres located at 66 S. Painter Rd.
approximately 0'.6 miles north of the main entrance to WCU campus. There would be no
impacts to Waters of The US under this alternative. The parcel meets the Criteria 1 of
proximity to campus and Criteria 2 of at least 10 acres for additional athletic field space..
However; due to topographic constraints, this location has poor connectivity to campus for
pedestrian and vehicle access and would require the construction of additional parking
beyond the proposed 50 spaces. This parcel is under private ownership and is not currently
listed for sale. Therefore, Alternative 3a has been eliminated from consideration.
Alternative 3b is a parcel #7558-25-8590 consisting of 20.5 acres located at 276 Parker Farm
Rd. approximately 1.5 miles south of the main entrance to WCU campus. Approximately 965
LF of perennial stream channel bisects this parcel, and 750 LF of perennial stream channel
forms the northern parcel boundary. Development of this alternative for the project purpose
would possibly result in impacts to Waters of The US. The parcel does not meet Criteria 1 of
proximity to campus and would require the construction of additional parking beyond the
proposed 50 spaces. The parcel does meet Criteria 2 of at least 10 acres for additional athletic
field space. This parcel is under private ownership and is not currently listed for sale.
Therefore, Alternative 3b has been eliminated from consideration.

Western Carolina University Master Plan Improvements
Permit Modification request
December 12, 2019
Page 5 of 6
No Action Alternative
There would be no impacts to Waters of The US under this alternative. If the no -action
alternative were chosen, the project purpose would not be met. Therefore, the no -action
alternative has been eliminated from consideration.
Cultural Resources
In August 2018 TRC Environmental Corporation released an addendum report on the archaeological
investigation conducted,, in the vicinity of the intramural fields improvements. The Permit Area for
Section 106 Review was confined to the immediate vicinity of wetland impacts proposed in the
USACE 404 permit and DWQ 401 Certification dated January 9, 2019 and September 21, 2019.
There are no recorded archaeological sites in or adjacent to the proposed permit area. There are six
previously recorded archaeological sites within a one-half mile radius of the project, including the
31JK2 (Cullowhee Mount and Village site). The survey consisted of systematic excavation of shovel
tests at 10-20 in intervals within and adjacent to the impact area and associated drainage and access
corridors. No artifacts were recovered from the 40 total shovel tests. Based on these results, no
further archaeological investigations were recommended for the project.
In a Pre -application meeting dated October 30, 2019 project stakeholders met onsite with the TRC
cultural resources manager Paul Webb to discuss archaeological resources in the vicinity of the
intramural fields. Archaeological investigations are ongoing at the Norton Field site (site 31JK615).
The investigations conducted to date have included survey and site evaluation as well as data
recovery work at site 31JK615, a large multi -component (primarily Mississippian period [Pisgah
phase] and Historic Cherokee [Qualla phase]) site. The fieldwork at site 31JK615 is ongoing and is
expected to be essentially completed by early January 2020. Proposed stockpile fill areas will be
backfilled on top of the archaeological site after fieldwork has been finalized. An interim fieldwork
report is included in Attachment B.
Mitigation
WCU has previously completed the required mitigation payments that account for 500 feet of stream
mitigation and 0.383 acre of wetlands. WCU paid the Division of Mitigation Services (DMS) for
wetland mitigation and stream mitigation on January 18, 2019 ($563,817.34) for 1,000 Cold Stream
credits and 0.53 Riparian Wetland credits.
Wetland Mitigation
Based on the proposed modification request, WCU impacts will total 0.733 acres of riparian
wetland. In order to comply with this modification request, WCU will mitigate for
additional wetland impact of 0.35 acres. CEC conducted an assessment of the quality of
wetlands proposed for impacts using the North Carolina Wetland Assessment Method
(NCWAM). NC WAM forms and results are included with this report in Attachment C.
Mitigation will include 1:1 mitigation through DMS (Attachment D).
Stream Mitigation
There are no changes to stream impacts or mitigation requested with this modification.
Stream impacts for the Master Plan Improvements to date (including this modification) will
total 500 linear feet of stream, wetland impacts total 0.733 acres, and open waters/ponds
total 0.47 acres.

Western Carolina University Master Plan Improvements
Permit Modification request
January 7, 2020
Page 6 of 6
Stormwater
The stormwater generated on site will be treated with a bioretention cell capable of capturing the
runoff from the first inch of rainfall. The applicant will submit the stormwater plan to the NC
Division of Water Resources for review ands approval. Please see Figure 5A for stormwater
management plans.
Floodplain
The site is looted in a Federal Emergency Management Agency (FEMA) 100-year floodplain
(Figure 7). The applicant will apply for a floodplain development permit from the NC Department of
Administration State Construction Office before earth moving activities begin.
Summary _
WCU respectfully requests that their 404 permit and 401 Water Quality Certification be modified to
accurately reflect completed or planned open water, stream, and wetland impacts, based on the
additional information in this submittal. If you have any questions or comments concerning the
information provided, please do not hesitate to contact me at 828-698-9800.
Sincerely,
6V"':z
AleaK. Tuttle, P.W.S.
Biologist
cc: Mr. Zan Price, NCDWR
Mr. Kevin Mitchell, NCDWR
Mr. Byron Hamstead, USFWS
Ms. Andrea Leslie, NCWRC
R Clement Riddle, P.W.S.
Principal

Western Carolina University Master Plan Improvements
Permit Modification request
December 12, 2019
Page 6 of 6
Stormwater
The stormwater generated on site will be treated with a bioretention cell capable of capturing the
runoff from the first inch of rainfall. The applicant will submit the stormwater plan to the NC
Division of Water Resources for review ands approval. Please see Figure 5A for stormwater
management plans.
Floodplain
The site is located in a Federal Emergency Management Agency (FEMA) 100-year floodplain
(Figure 7). The applicant will apply for a floodplain development permit from the NC Department of
Administration State Construction Office before earth moving activities begin.
Summary
WCU respectfully requests that their 404 permit and 401 Water Quality Certification be modified to
accurately reflect completed or planned open water, stream, and wetland impacts, based on the
additional information in this submittal. If you have any questions or comments concerning the
information provided, please do not hesitate to contact me at 828-69879800.
Sincerely,
Alea K. Tuttle, P.W.S.
Biologist
cc: Mr. Zan Price, NCDWR
Mr. Kevin Mitchell, NCDWR
Mr. Byron Hamstead, USFWS
Ms. Andrea Leslie, NCWRC
R. Clement Riddle, P.W.S.
Principal

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32 Clayton Street
Asheville, North Carolina 28801

WCU Master Plan Improvements

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32 Clayton Street
Asheville, North Carolina 28801

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WCU Master Plan Improvements
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Asheville, North Carolina 28801

Western Carolina University Master Plan Improvements
Adjoining Property Owners
Map
OWNER
OWNER
SITE
PARCEL NO
I
MAILING ADDRESS
CITY
STATE
ZIP
#
NAME
NAME2
ADDRESS
CATAMOUNT PEAK PHASE I
85 POINTE
0
7558-39-9837
PO BOX 99568
RALEIGH
NC
27624
LLC
LN
TR 3, 4
CATAMOUNT PEAK PHASE II
1
7559-30-7466
PO BOX 99568
RALEIGH
NC
27624
SPEEDWELL
LLC
RD
324
324 BUZZARDS
2
7559-25-5030
ASHBROOK, BETTY J
CULLOWHEE
NC
28723
BUZZARDS
ROOST RD
ROOST RD
8W
3
7559-25-3032
MULLIGAN, ROBERT F
165 S 21ST ST
RICHMOND
IN
47374
BUZZARDS
ROOST RD
372
4
7559-30-4191
HOLLIS, MARY ANN
PO BOX 1327
CULLOWHEE
NC
28723
SPEEDWELL
RD
341
HILLON,
HILLON, YUE
5
7559-25-4109
PO BOX 3596
CULLOWHEE
NC
28723
BUZZARDS
MARK ETAL
C
ROOST RD
298
BRANDT,
BRANDT,
6
7559-30-4262
PO BOX 3276
CULLOWHEE
NC
28723
SPEEDWELL
RODERICKJ
TRACY
RD
22 W
GOODSON, T
GOODSON,
7
7559-24-3865
PO BOX 1002
SYLVA
NC
28779
BUZZARDS
HART
SARA
ROOST RD
23 W
HUGUELET,
VAUGHN,
8
7559-24-5965
1355 FAIRVIEW RD
SYLVA
NC
28779
BUZZARDS
WILLIAM R
KIMBERLY A
ROOST RD
269
WILSON, GAIL CANNON
9
7559-24-6922
3600 PRYTANIA ST
NEW ORLEANS
LA
70115
BUZZARDS
TRUSTEE
ROOST RD
WILLIAMS,
WILLIAMS,
23TERRACE
10
7559-54-0876
35STEWARTST
TOCCOA
GA
I
30577
I
FRED A
JUDY D
VILLAGE DR
pg. 1

Western Carolina University Master Plan Improvements
Adjoining Property Owners
MAULDIN,
MAULDIN,
ill
11
7559-33-0689
NANCY
GARY
PO BOX 219
CULLOWHEE
NC
28723
RESERVOIR
TRUSTEE
TRUSTEE
RIDGE DR
262
SMITH, KELLY
RANDY
12
7559-31-1781
141 JONES TRL
BRYSON CITY
NC
28713
CULLOWHEE
A
YACUZZO
HTS
CULLOWHEE BAPTIST
82 CENTRAL
13
7559-35-8382
PO BOX 37
CULLOWHEE
NC
28723
CHURCH
DR
3477 OLD
14
7559-45-9384
ROBERTSON, JERALD DUANE
PO BOX 218
CULLOWHEE
NC
28723
CULLOWHEE
RD
61 MERLITE
15
7559-43-1131
WARD, DAVID BRIAN
PO BOX 2782
CULLOWHEE
NC
28723
CT
415
415 BUZZARDS
16
7559-25-7368
MCDONALD, MICHELLE K
CULLOWHEE
NC
28723
BUZZARDS
ROOSTRD
ROOST RD
189
MORGAN,
MORGAN,
189 BUZZARDS
17
7559-35-0267
CULLOWHEE
NC
28723
BUZZARDS
RONALD
HILDEGARD
ROOSTRD
ROOST RD
29 PENCIL
18
7559-54-1698
WRIGHT, RICHARD L
PO BOX 95
SYLVA
NC
28779
UN
OLD
19
7559-54-1873
ROBERTSON, JERALD DUANE
PO BOX 218
CULLOWHEE
NC
28723
CULLOWHEE
RD
BROWN,
BROWN,
119 DUBLIN
RESERVOIR
20
7559-32-8461
CARY
NC
27513
FRANK III
CARRAH A
WOODS DR
RIDGE RD
OVERLOOK
21
7559-35-1769
RYMELL, MICHAEL P
97 OVERLOOK DR
CULLOWHEE
NC
28723
DR
ED NORTON
22
7559-42-1661
BRYSON, JIMMIE P HEIRS
PO BOX 93
CULLOWHEE
NC
28723
RD
145 S BONNIE
SOUTH
23
7559-16-5766
HUNDLEY, HELEN SHARON
WICHITA
KS
67207
BRAE ST
PAINTER RD
PR 2

Western Carolina University Master Plan Improvements
Adjoining Property Owners
37
24
7559-25-8575
BURTON, CAROL
PO BOX 1974
CULLOWHEE
NC
28723
OVERLOOK
DR
BYER, JAMES
25
7559-26-9266
PO BOX 489
CULLOWHEE
NC
28723
TRACER LN
KATHRYN S
115
CULLOWHEE METHODIST
26
7559-33-5828
PO BOX 2454
CULLOWHEE
NC
28723
RESERVOIR
CHURCH
RIDGE DR
ALL PRO PROP
15A PHOENIX
62 PENCIL
27
7559-54-2554
SYLVA
NC
28779
MANAGEMENT INC
VALLEY DR
LN
147
HILLON,
HILLON, YUE
28
7559-35-0384
PO BOX 3596
CULLOWHEE
NC
28723
BUZZARDS
MARK
C
ROOST RD
22
29
7559-35-1540
WREN AND RAVEN LLC
PO BOX 2765
CULLOWHEE
NC
28723
OVERLOOK
DR
MESSER, JOE
MESSER,
301 SOUTH
30
7559-16-8872
321 S PAINTER RD
CULLOWHEE
NC
28723
E
BONNIE
PAINTER RD
ED NORTON
110 ED
31
7559-42-4323
CLAYTON, CATHERINE
RD
CULLOWHEE
NC
28723
RD
285 SOUTH
32
7559-16-9851
TAYLOR, ANDREA N
10517 S KILDARE
OAK LAWN
IL
60453
PAINTER RD
BYER, JAMES
BYER,
127 TRACER
33
7559-36-0056
PO BOX 489
CULLOWHEE
NC
28723
E
KATHRYN S
LN
N C DEPT OF
34
7559-06-9747
1594 E MAIN ST
SYLVA
NC
28779
HWY 107
TRANSPORTATION
C/O BRETT CORBIN
415 SOUTH
35
7559-16-4708
BC CULLOWHEE LLC
SAN DIEGO
CA
92169
PO BOX 90429
PAINTER RD
LT 1,2 A
145 5 BONNIE
36
7559-16-7565
HUNDLEY, HELEN SHARON
WICHITA
KS
67207
SOUTH
BRAE ST
PAINTER RD
pg. 3

Western Carolina University Master Plan Improvements
Adjoining Property Owners
370
WHITE,
WHITE,
370 BUZZARDS
37
7559-25-6135
CULLOWHEE
NC
28723
BUZZARDS
STEPHENM
ELAINES
ROOSTRD
ROOST RD
QUEEN,
CEO FRANK QUEEN
QUEEN,
247SOUTH
38
7559-26-1757
JAMES RJR
154 N MAIN 5TSTE
WAYNESVILLE
NC
28786
BUFFY
PAINTER RD
ETAL
2
FRANKS,
FRANKS,
121 DERBY
39
7558-39-1662
9TRUMPET DR
CULLOWHEE
NC
28723
HAROLD B
CYNTHIA B
RD
BYER, JAMES
40
7559-35-1942
PO BOX 489
CULLOWHEE
NC
28723
TRACER LN
KATHRYN
225
HILLON,
HILLON, YUE
41
7559-25-8053
PO BOX 3596
CULLOWHEE
NC
28723
BUZZARDS
MARK
C
ROOST RD
GRIESSER,
GRIESSER,
110
42
7559-35-6932
ARTHUR
DIANE
PO BOX 2765
CULLOWHEE
NC
28723
BUZZARDS
FRANCIS
SIMONS
ROOST RD
151 ED
43
7559-42-1512
BRYSON, JIMMIE P HEIRS
PO BOX 93
CULLOWHEE
NC
28723
NORTON RD
BYER, JAMES
BYER,
51 TRACER
44
7559-26-8424
PO BOX 489
CULLOWHEE
NC
28723
E
KATHRYN S
LN
167
45
7559-33-5576
BOO, ALICIA DEANS
PO BOX 2865
CULLOWHEE
NC
28723
RESERVOIR
RIDGE DR
BRYSON,
BRYSON,
209 SOUTH
46
7559-26-3743
209 S PAINTER RD
CULLOWHEE
NC
28723
STEVE A
CINDY S
PAINTER RD
3344 OLD
47
7559-45-4113
VIPKOL LLC
PO BOX 296
WEBSTER
NC
28788
CULLOWHEE
RD
97
48
7559-35-2616
RYMELL MICHAEL P
97 OVERLOOK DR
CULLOWHEE
NC
28723
OVERLOOK
DR
HALEY, JED A
GRIESSER,
432 ROCKING
STEDMAN
49
7559-35-7741
FRANKLIN
NC
28734
ETAL
ARTHUR F
CHAIR LANE
DR
Pg. 4

Western Carolina University Master Plan Improvements
Adjoining Property Owners
141
BUCHANAN,
BUCHANAN,
141 MONTEITH
50
7559-36-3172
CULLOWHEE
NC
28723
MONTEITH
MICHAEL R
MILDRED
GAP RD
GAP RD
96
51
7559-35-7951
HALEY, JED ALLEN
PO BOX 3143
CULLOWHEE
NC
28723
STEDMAN
DR
C/O BARBARA
62
MOUNTAIN PROPERTIES OF
52
7559-22-8355
COOK505HADY
FRANKLIN
NC
28734
CULLOWHEE
NC LLC
OAKS DR
HTS
BUSBIN,
BUSBIN,
54LEGACY
53
7559-23-8263
JAMES
PO BOX 1546
WHITTIER
NC
28789
JULIE
LN
WALKER II
3697 OLD
TUCKASEIGEE WATER &
54
7559-53-5343
1246 W MAIN ST
SYLVA
NC
28779
CULLOWHEE
SEWER AUTH
RD
96 SULPHUR
55
7559-30-2882
HALEY, JED ALLEN
PO BOX 3143
CULLOWHEE
NC
28723
SPRINGS RD
2425 N CENTER ST
36 DIXS GAP
56
7559-42-9761
RAP HOLDINGS II LLC
HICKORY
NC
28601
UNIT 352
CIR
JACOBSEN,
JACOBSEN,
GUDGER
57
7559-63-4495
FRED
MAUDE
1628215TSTNW
WASHINGTON
DC
20009
HILL RD
TRUSTEE ETAL
TRUSTEE
150
4258 PARKVIEW
STONE
58
7559-30-6863
THOMAS, GLENDA M
GA
30083
SULPHUR
CT
MOUNTAIN
SPRINGS RD
35 DIXS GAP
59
7559-52-2800
ANDREWS, JUDITH TRUSTEE
PO BOX 344
CULLOWHEE
NC
28723
CIR
HUGUELET,
HUGUELET,
35 GUDGER HILL
CULLOWHEE
35 GUDGER
60
7559-53-3877
NC
28723
CHARLES
DONNA
RD
NC
HILL RD
41
FARMER,
JAMESC
109CULLOWHEE
61
7559-22-8667
CULLOWHEE
NC
28723
CULLOWHEE
BETTY
MANNING
HEIGHTS
HTS
pg. 5

Western Carolina University Master Plan Improvements
Adjoining Property Owners
900E CENTRE
286FOREST
62
7559-22-9197
EPISCOPAL DIOCESE OF WNC
ASHEVILLE
NC
28805
PARK DR
HILLS RD
BUSBIN,
BUSBIN,
44 LEGACY
63
7559-23-8373
JAMES
PO BOX 1546
WHITTIER
NC
28789
JULIE
LN
WALKER II
416 FOREST
64
7559-22-7884
BEGLEY, MICHAELI
PO BOX 36776
CHARLOTTE
NC
28236
HILLS RD
93 DIX GAP CR PO
93 DIXS GAP
65
7559-42-7415
PEEBLES, WILLIAM LOUIS
CULLOWHEE
NC
28723
BOX 2223
CIR
234
66
7559-31-0411
BROWN, DON L
PO BOX 452
CULLOWHEE
NC
28723
CULLOWHEE
HTS
OLD
TUCKASEIGEE WATER &
67
7559-52-4899
1246 W MAIN ST
SYLVA
NC
28779
CULLOWHEE
SEWER AUTH
RD
ACKART,
ACKART,
824 NEWBERGER
68LEGACY
68
7559-23-7083
LUTZ
FL
33549
ROBERTT
JENNIFERC
RD
LN
594
CULLOWHEE PRESBYTERIAN
114 SILVER CREEK
69
7559-23-9518
MORGANTON
NC
28655
CENTENNIAL
CHURCH
RD
DR
3579 OLD
70
7559-54-3104
MOUNT ZION AME CHURCH
PO BOX 2762
CULLOWHEE
NC
28723
CULLOWHEE
RD
328
71
7559-31-1979
BACHUS, RAE
PO BOX 338
CULLOWHEE
NC
28723
CULLOWHEE
HTS
1061 ALTAMONT
STEDMAN
72
7559-45-2228
MOSS HOLDINGS LLC ETAL
GREENVILLE
Sc
29609
RD
DR
OLD
TUCKASEIGEE WATER &
73
7559-55-0610
1246 W MAIN ST
SYLVA
NC
28779
CULLOWHEE
SEWER AUTH
RD
TVA LAND BRANCH
111 CASEY
74
7559-45-7664
UNITED STATES OF AMERICA
CHATTANOOGA
TN
37415
464 LUPTON DR
RD
pg. 6

Western Carolina University Master Plan Improvements
Adjoining Property Owners
OLD
CALDERBANK, JAMES M
281 BRUNSWICK
75
7559-45-2590
WAYNESVILLE
NC
28786
CULLOWHEE
TRUSTEE
RD
RD
KELLY,
PRESSLEY,
19 CAMPER
76
7559-45-3609
PO BOX 1065
CULLOWHEE
NC
28723
JENNIFER P
CHRIS
LN

Attachment A
USACE 404 Permit Authorization SAW-2015-00263; January 9, 2019
and
NC DWR 401 Certification No. 20180612; September 21, 2019

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATT AVENUE
ROOM
208
ASHEVQ.LE, NORTH CAROLINA 28801-5006
January 9, 2019
Regulatory Division
Action ID: SAW SAW-2015-00263
Mr. Joe Walker
Associate Vice Chancellor, Facilities Management
Western Carolina University
3476 Old Cullowhee Road
Cullowhee, North Carolina 28723
Dear Mr. Walker:
Enclosed is a Department of the Army permit to place fill in 500 linear feet of stream
channel and 0.38 acres of wetlands, resulting in impacts to waters of the U.S.,
associated with the Western Carolina University 2014 Master Plan Improvement
Projects (Central Drive parking lot and intramural fields improvements). The above
noted impacts are 500 linear feet of permanent stream impacts to a UT of Cullowhee
Creek (parking lot construction); 0.293 acres of permanent wetland impacts (parking lot
construction); and 0.09 acres of permanent wetland impacts (intramural fields
improvements). The Corps is Issuing this permit in response to your written request of
May 3, 2018, and the ensuing administrative record.
Any deviation in the authorized work will likely require modification of this permit. If a
change in the authorized work is necessary, you should promptly submit revised plans
to the Corps showing the proposed changes. You may not undertake the proposed
changes until the Corps notifies you that your permit has been modified.
Carefully read your permit. The general and special conditions are important. Your
failure to comply with these conditions could result in a violation of Federal law. Certain
significant conditions require that:
a. You must complete construction before January 9, 2024.
.b. You must notify this office in advance as to when you intend to commence and
complete work.
c. You must allow representatives from this office to make periodic visits to your
worksite as deemed necessary to assure compliance with permit plans and
conditions.

-2-
d. In order to compensate for impacts associated with this permit, mitigation shall
be provided in accordance with the provisions outlined in the U.S. Army Corps of
Engineers,. Wilmington District, Compensatory Mitigation Responsibility Transfer
Form. The requirements of this form, including any special conditions listed on
this form, are hereby incorporated as special conditions of this permit
authorization.
You should address all questions regarding this authorization to Mr. David Brown at
the Asheville Regulatory Field Office, telephone [phone] extension 4232.
FOR THE COMMANDER
Sincerely,
.=B MICMAflSCOR.m9319C73
•DbY a.US o-U.S. Gwnrimmt ou-MD, owPiG,
oL-M& m-MESAyC M-14=1756314073
Date:1014A1L91p:1&T3 -03ti7
M. Scott Jones
Chief
Asheville/Chadotte Regulatory Field Offices
Enclosures
cc (with enclosures):
NOAA/National Ocean Service
1315 East -west Hwy., Rm 7316
Silver Spring, Maryland 20910-3282
Mr. Byron Hamstead
U.S. Fish and Wildlife Service
.160 Zillicoa Street
Asheville, North Carolina 28801
Dr. Ken Riley
National Marine Fisheries Service
Habitat Conservation Division
101 Pivers Island. Road
Beaufort, North Carolina 28516
Mr. Todd Bowers
Wetlands Protection Section — Region IV
Water Management Division
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303

I
DEPARTMENT OF THE ARMY PERNIIT
Permittee Western Carolina University
Permit No. SAW 2015-00263
Issuing office CESAW RG A
NOTE: The term "you" and Its derivatives, as used in this permit, means the permittee or any future transferee. The
term "this office" refers to the appropriate district or division office of the Corps of Engineers having jurisdiction over
the permitted activity or the appropriate official of that office acting under the authority of the commanding officer.
You are authorized to perform work in accordance with the terms and conditions specified below.
Project Description:
To place fill in 500 linear feet of stream channel and 0.39 acres of wetlands, resulting in impacts to waters of the U.S., associated
with the Western Carolina University 2014 Master Plan Improvement Projects (Central Drive parking lot and intramural fields
improvements). The above noted impacts are 500 linear feet of permanent stream impacts to a UT of Cullowhee Creek (parking
lot construction); 0.293 acres of permanent wetland impacts (parking lot construction); and 0.09 acres of permanent wetland
impacts (intramural fields improvements).
Project Location:
Cullowhee, Jackson County, North Carolina.
Permit Conditions:
General Conditions:
1. The time limit for completing the work authorized ends on 12/27/2023 . If you find that you need more
time to complete the authorized activity, submit your request for a time extension'to this office for consideration at
least one month before the above date is reached.
2. You must maintain the activity authorized by this permit in good condition and in conformance with the terms and
conditions of this permit. You are not relieved of this requirement if you abandon the permitted activity, although you
may make a good faith transfer to a third party in compliance with General Condition 4 below. Should you wish to
cease to maintain the authorized activity or should you desire to abandon it without a good faith transfer, you must
obtain a modification of this permit from this office, which may require restoration of the area.
3. If you discover any previously unknown historic or archeological remains while accomplishing the activity
authorized by this permit, you must immediately notify this office of what you have found. We will Initiate the Federal
and state coordination required to determine If the remains warrant a recovery effort or if the site is ellgible for listing
in the National Register of Historic Places.
4. If you sell the property associated with this permit, you must obtain the signature of the new owner in the space
provided and forward a copy of the permit to this office to validate the transfer of this authorization. .
ENO FORM 1721, Nov 86 EDITION OF SEP 82 IS OBSOLETE. (33 CPR 325 (Appendix A))

.S
5. If a conditioned water quality certification has been issued for your project, you must comply with the conditions
specified in the certification as special conditions to this permit. For your convenience, a copy of the certification is
attached if it contains such conditions.
6. You must allow representatives from this office to inspect the authorized activity at any time deemed necessary
to ensure that it is being or has been accomplished in accordance with the terms and conditions of your permit,
Special Conditions:
SEE ATTACHED SPECIAL CONDITIONS
Further Information:
1. Congressional Authorities: You have been authorized to undertake the activity described above pursuant to:
❑ Section 10 of the Rivers and Harbors Act of 1899 (33 U.S.C. 403).
❑✓ Section 404 of the Clean Water Act (33 U.S.C. 1344).
❑ Section 103 of the Marine Protection, Research and Sanctuaries Act of 1972 (33 U.S 1413).
2. Limits of this authorization.
a. This permit does not obviate the need to obtain other Federal, state, or local authorizations required by law.
b. This permit'does not grant any property rights or exclusive privileges.
c. This permit does not authorize any injury to the property or rights of others.
d. This permit does not authorize interference with any existing or proposed Federal project
3. Limits of Federal Liability. In issuing this permit, the Federal Government does not assume any liability for the
following:
a. Damages to the permitted project or uses thereof as a result of other permitted or unpermitted activities or
from natural causes.
b. Damages to the permitted project or uses thereof as a result of current or future activities undertaken by or
on behalf of the United States in the public interest.
c. Damages to persons, property, or to other permitted or unpermitted activities or structures caused by the
activity authorized by this permit
d. Design or construction deficiencies associated with the permitted work.
e. Damage claims associated with any future modification, suspension, or revocation of this permit.
4. Reliance on Applicant's Data: The determination of this office that issuance of this permit is not contrary to the
public interest was made in reliance on the information you provided.
(REVERSE OF ENG FORM 1721)
2

5. Reevaluation of Permit Decision. This office may reevaluate its decision on this permit at any time the
circumstances warrant. Circumstances that could require a reevaluation include, but are not limited to, the
following:
a. You fail to comply with the terms and conditions of this permit.
b. The information provided by you in support of your permit application proves to have been false,
incomplete, or inaccurate (See 4 above).
b. Significant new information surfaces which this office did not consider in reaching the original public interest
decision.
Such a reevaluation may result In a determination that it is appropriate to use the suspension, modification, and
revocation procedures contained in 33 CFR 325.7 or enforcement procedures such as those contained in 33 CFR
326.4 and 326.5. The referenced enforcement procedures provide for the issuance of an administrative order
requiring you to comply with the terms and conditions of your permit and for the Initiation of legal action where
appropriate. You will be required to pay for any corrective measures ordered by this office, and If you fail to comply
with such directive, this office may in certain situations (such as those specified in 33 CFR 209.170) accomplish the
corrective measures by contract or otherwise and bill you for the cost.
6. Extensions. General condition t establishes a time limit for the completion of the activity authorized by this permit,
unless there are circumstances requiring either a prompt completion of the authorized activity or a reevaluation
of the public interest decision, the Corps will normally give favorable consideration to a request for an extension
of this time limit.
Your signature below, as permittee, indicates that you accept and agree to comply with the terms and conditions of
this permit.
y
(PERMITTE STERN CAROLINA UNIVERSITY ( ATE)
This permit becomes effective when the Federal official, designated to act for the Secretary of the Army, has signed
below.
(DISTRICT COMMAVDERN16BERT J, CLARK (DATE)
COLONEL, U.S. ARMY
DISTRICT COMMANDER
When the structures or work authorized by this permit are still in existence at the time the property is transferred, the
terns and conditions of this permit will continue to be binding on the new owner(s) of the property. To validate the
transfer of this permit and the associated liabilities associated with compliance with its terms and conditions, have
the transferee sign and date below.
(TRANSFEREE)
(DATE)
*U.S. GOVERNMENT PRrfMO OFFICE: 1996 - 717425

ROY COOPER
Gm.anw
MICHAEL S. REGAN
5n retary
LINDA CULPEPPER
lorr•rim, Arcefa
Western Carolina University
Attn: Joe Walker, P.E.
3476 Old Cullowhee Rd
Cullowhee NC 28723
NOR] H CAROLINA
Envtromnenror Quarity
September 21, 2018
DWR H 2O180612
Jackson County
Subject: Approval of Individual 401 Water Quality Certification with Additional Conditions
Western Carolina University Master Plan Improvements
USACE Action ID. No. SAW-2015-00263
Dear Mr. Walker:
Attached hereto is a copy of Certification No. WQC004170 issued to Mr. Joe Walker and
Western Carolina University, dated September 21, 2018. Please note that you should get
any other federal, state or local permits before proceeding with the subject project,
including those required by (but not limited to) Sediment and Erosion Control, Non -
Discharge, and Water Supply Watershed regulations.
This approval and its conditions are final and binding unless contested. This Certification can be
contested as provided in General Statute 150B by filing a written petition for an administrative
hearing to the Office of Administrative Hearings (hereby known as OAH) within sixty (60)
calendar days.
A petition form maybe obtained from the OAH at http://www.ncoah.com/ or by calling the
OAH Clerk's Office at [phone] for information. A petition is considered filed when the
original and one (1) copy along with any applicable OAH filing fee is received in the OAH during
normal office hours (Monday through Friday between 8:00am and 5:00pm, excluding official
state holidays).
The petition may be faxed to the OAH at [phone], provided the original and one copy of
the petition along with any applicable OAH filing fee is received by the OAH within five (5)
business days following the faxed transmission.
L.r"i'r:fr' LT�
C;.w`ma 1XVF mm110 F•1. I Cpplganl Quallt) 1)nr_:1: td V%Al" kosowei.
W 2 tin❑ so shu.v Sl,awt , 16] 1 A:nd seller cep;u Ras: i I, ru;P. ca.am: 4 i69161 i
919 707.9060

Western Carolina University Master Plan Improvements
DWR Project #20180612
Individual Certification #4170
Page 2 of 8
Mailing address for the OAH:
if sending via US Postal Service: !f sending via delivery service (UPS, FedEx, etc):
Office of Administrative Hearings Office of Administrative Hearings
6714 Mail Service Center 1711 New Hope Church Road
Raleigh, NC 27699-6714 Raleigh, NC 27609-6285
One (1) copy of the petition must also be served to DEC;
William F. Lane, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh, NC 27699-1601
Unless such a petition is filed, this Certiftation shall be final and binding.
This certification completes the review of the Division under section 401 of the Clean Water Act
and 15A NCAC 02H .0500. Contact Sue Homewood at 336-776-9693 or
[e-mail] if you have any questions or concerns.
Sincerely, _
Karen Higgins, Supervi
401 & Suffer Permitting ranch
cc: Clement Riddle, ClearWater Environmental Consultants Inc (via email)
David Brown, USACE Asheville Regulatory Field Office (via email)
Andrea Leslie, NCWRC (via email)
Byron Hamstead, FWS (via email)
Todd Bowers, EPA, (via email)
DWR ARO 401 file
DWR 401 & Buffer Permitting Branch file
Fllename:180612WesternCaroiinaUnlversityMasterPlanimprovements(Jackson) 401 IC

Western Carolina University Master Plan Improvements
DWR Project #20180612
Individual Certification #4170
Page 3 of 8
NORTH CAROLINA 401 WATER QUALITY CERTIFICATION
CERTIFICATION # WQ0004170 is issued in conformity with the requirements of Section 401,
Public Laws 92-500 and 95-217 of the United States and subject to North Carolina's Regulations in
15 NCAC 02H .0500, to Mr. Joe Walker and Western Carolina University, who have authorization
for the impacts listed below, as described within your application received by the N.C. Division of
Water Resources (Division) on May 3, 2018 and subsequent information on June 29, 2018, August
9, 2018, August 13, 2018 and August 31, 2018, and by Public Notice issued by the U. S. Army
Corps of Engineers and received by the Division on May 17, 2018.
The State of North Carolina certifies that this activity will not violate the applicable portions of
Sections 301, 302, 303, 306, 307 of the Public Laws 92-500 and PL 95-217 if conducted in
accordance with the application, the supporting documentation, and conditions hereinafter set
forth:
This approval requires you to follow the conditions listed in the certification below.
Conditions of Certification:
1. The following impacts are hereby approved provided that all of the other specific and
general conditions of the Certification are met. No other impacts are approved, including
incidental impacts. [15A NCAC 02H .0506(b) and/or (c)]
Type of impact
Amount Approved
(units)
Permanent
Amount Approved
(units)
Temporary
Stream
Central Drive Lot T500 (linear feet)
0 (linear feet}
404/401 Wetlands
Central Drive Lot
0.293 (acres)
0 (acres)
Intramural Fields
0.09 (acres)
0 (acres)
2. Mitigation must be provided for the proposed impacts as specified in the table below. The
Division has received an acceptance letter from the NC Division of Mitigation Services (DMS)
to meet this mitigation requirement. Until the DMS receives and clears your payment, and
proof of payment has been provided to this Office, no impacts specified in this
Authorization Certificate shall occur. For accounting purposes, this Authorization Certificate
authorizes payment to the DMS to meet the following compensatory mitigation
requirement 115A NCAC 021-1.0506 (b)(6)]:

.. S
Western Carolina University Master Plan Improvements
DWR Project#20180612
Individual Certification #4170
Page 4 of 8
Compensatory Mitigation
River & Sub -basin Number
Required
Stream
500 (linear feet)
Little Tennessee
LTN02
3. The Division approves the Stormwater Management Plan (SMP) consisting of a proprietary
system, Contech StormFilters and all associated stormwater conveyances, Inlet and outlet
structures,_ and the grading and drainage patterns depicted on plan sheets dated June 27,
2018, whic are incorporated by reference and are enforceable by the Division. The
following conditions also apply (15A NCAC 02H .0506(b)(5)]:
a. The maximum allowable drainage area for the approved Contech StormFiliers shall be
182,737 square feet and the maximum allowable built -upon area within that drainage
area shall be 149,076 square feet. Any changes to these allowable maximum areas
shall require the applicant to submit and receive approval from the Division prior to any
construction or modification of the current site.
b. The footprint of all stormwater management device(s) -as well as an additional 11-foot
wide area on all sides of the device(s) shall be located in either public rights -of -way,
dedicated common areas or recorded easement areas. The final plats for the project
showing such rights -of -way, common areas and easement areas, shall be in accordance
with the approved plans.
c. The approved SMP shall be constructed and operational before any permanent building
or other structure is occupied at the site.
d. The SMP may not be modified without prior written authorization from the Division.
e. Maintenance activities for stormwater management device(s) shall be performed in
accordance with the notarized 0&M agreements signed by Joe Walker on August 30,
2018. The 0&M agreement shall transfer with the sale of the land or transfer of
ownership/responsibility for the approved diffuse flow plan. The Division shall be
notified promptly of every transfer.
f. The applicant and/or authorized agent shall provide a completed Certificate of
Completion form to the Division within thirty (30) days of project completion (available
at httys:Hedocs.deQ.nc.aoy/Forms/Certificate-of-Completion).
4. To protect rare and listed species in the Tuckasegee River, the erosion control plan will be
designed to the 25-year storm event and ground disturbance shall be limited to what will be
stabilized within 7 calendar days or either reaching finished grade or stopping work In an
area. (15A NCAC 02H .0506(b)(2) and 15A NCAC 048.0125]
5. This approval is for the purpose and design described in your application and as described in
the Public Notice. The plans and specifications for this project are incorporated by reference
and are an enforceable part of the Certification. Any modifications to the project require
notification to DWR and may require an application submittal to DWR with the appropriate
fee. j15A NCAC 02H .0501 and .0502j

Western Carolina -University Master Plan Improvements
DWR Project #20180612
Individual Certification #4170
Page 5 of 8
6. No waste, spoil, solids, or fill of any kind shall occur in wetlands or waters beyond the
footprint of the Impactsf(including temporary impacts) as authorized under this Certification.
[15A NCAC 02H ,0501 and .0502]
7. All construction activities shall be performed and maintained in full compliance with G.S.
Chapter 113A Article 4 (Sediment and Pollution Control Act of 1973).
8. Sediment and erosion control measures shall not be placed in wetlands or waters except
within the footprint of temporary or permanent Impacts authorized under this Certification.
[15A NCAC 02H .0501 and .0502]
9. Erosion control matting that incorporates plastic mesh and/or plastic twine shall not be
used along streambanks or within wetlands. [15A NCAC 02B .0201]
10. An NPDES Construction Stormwater Permit (NCG010000) is required for construction
projects that disturb one (1) or more acres of land. The NCG010000 Permit allows
stormwater to be discharged during land disturbing construction activities as stipulated in
the conditions of the permit. if the project is covered by this permit, full compliance with
permit conditions Including the erosion & sedimentation control plan, inspections and
maintenance, self -monitoring, record keeping and reporting requirements is required. [15A
NCAC 02H .0506(b)(5) and (c)(5)]
11. All work in or adjacent to streams shall be conducted so that the flowing stream does not
come in contact with the disturbed area. Approved best management practices from the
most current version of the NC Sediment and Erosion Control. Manual, or the NC DOT
Construction and Maintenance Activities Manual, such as sandbags, rock berms, cofferdams,
and other diversion structures shall be used to minimize excavation in flowing water. [15A
NCAC 02H .0506(b)(3) and (c)(3)]
12. Culverts shall be designed and installed in such a manner that the original stream profiles are
not altered and allow for aquatic life movement during low flows. The dimension, pattern,
and profile of the stream above and below a pipe or culvert shall not be modified by widening
the stream channel or by reducing the depth of the stream in connection with the
construction activity. The width, height, and gradient of a proposed culvert shall be such as to
pass the average historical low flow and spring flow without adversely altering flow velocity.
[15A NCAC 02H .0506(b)(2) and (c)(2)].
Placement of culverts and other structures in streams shall be below the elevation of the
streambed by one foot for all culverts with a diameter greater than 48 inches, and 20% of the
culvert diameter for culverts having a diameter less than or equal to 48 inches, to allow low
flow passage of water and aquatic life.

Western Carolina University Master Plan improvements
DWR Project #20180612
Individual Certification #4170
Page 6 of 8
If bedrock is discovered during construction, then DWR shall be notified by phone or email
within 24 hours of discovery.
13. Application of fertilizer to establish planted/seeded vegetation within disturbed riparian
areas and/or wetlands shall be conducted at agronomic rates and shall comply with all other
Federal, State and Local regulations. fertilizer application shall be accomplished in a manner
that minimizes the risk of contact between the fertilizer and surface waters. [15A NCAC 02B
.0200 and 15A NCAC 02B .0231]
14. If concrete is used during construction, then all necessary measures shall. be taken to prevent
direct contact between uncured or curing concrete and waters of the state. Water that
inadvertently contacts uncured concrete shall not be discharged to waters of the state. [15A
NCAC 028.0200)
15. No temporary impacts are allowed beyond those included in this Certification. All temporary
fill and culverts shall be removed and the impacted area shall be returned to natural
conditions within 60 calendar days after the temporary impact is no longer necessary. The
impacted areas shall be restored to original grade, including each stream's original cross
sectional dimensions, planform pattern, and longitudinal, bed profile. All temporarily
impacted sites shall be restored and stabilized with native vegetation. [15A NCAC 02H
.0506(b)(2) and (c)(2)]
26. All proposed and approved temporary pipes/culverts/rip-rap pads etc. in streams shall be
installed as outlined in the most recent edition of the North Carolina Sediment and Erosion
Control Planning and Design Manual or the North Carolina Surface Mining Manual or the
North Carolina Department of Transportation Best Management Practices for Construction
and Maintenance Activities so as not to restrict stream flow or cause dis-equilibrium during
use of this Certification. [15A NCAC 02H .0506(b)(2) and (c)(2)]
17. Any riprap required for proper culvert placement, stream stabilization, or restoration of
temporarily disturbed areas shall be restricted to the area directly Impacted by the approved
construction activity. All riprap shall be buried and/or "keyed in" such that the original
stream elevation and streambank contours are restored and maintained. Placement of riprap
or other approved materials shall not result in de -stabilization of the stream bed or banks
upstream or downstream of the area. [15A NCAC 02H .0506(b)(2)]
18. This Certification does not relieve the applicant of the responsibility to obtain all other
required Federal, State, or Local approvals before proceeding with the project, including
those required by, but not limited to Sediment and Erosion Control, Non -Discharge, Water
Supply Watershed, and Trout Buffer regulations.

Western Carolina University Master Plan Improvements
DWR Project #20180612
individual Certification #4170
Page 7 of 8
19. All mechanized equipment operated near surface waters shall be inspected and maintained
regularly to prevent contamination of surface waters from fuels, lubricants, hydraulic fluids,
or other toxic materials. Construction shall be staged in order to minimize the exposure of
equipment to surface watersto the maximum extent practicable. Fueling, lubrication and
general equipment maintenance shall not take place within 50 feet of a waterbody or
wetlands to prevent contamination by fuels and oils. (15A NCAC 02H .0506(b)(3) and (c)(3)
and 15A NCAC 02B .0211(12)]
20. Heavy equipment working in wetlands shall be placed on mats or other measures shall be
taken to minimize soil disturbance. [15A NCAC 02H .0506(b)(3) and (c)(3))
21. In accordance with 143-215.85(b), the applicant shall report any petroleum spill of 25 gallons
or more; any spill regardless of amount that causes a sheen on surface waters; any petroleum
spill regardless of amount occurring within 100 feet of surface waters; and any petroleum
spill less than 25 gallons that cannot be cleaned up within 24 hours.
22. Mr. Joe Walker and Western Carolina University shall conductconstruction activities in a
manner consistent with State water quality standards (including any requirements resulting
from compliance with section 303(d) of the Clean Water Act) and any other appropriate
requirements of State and Federal law. [15A NCAC 02B .0200] if the Division determines that
such standards or laws are not being met (including the failure to sustain a designated or
achieved use) or that State or federal law is being violated, or that further conditions are
necessary to assure compliance, the Division may reevaluate and modify this Certification.
Before modifying the Certification, the Division shall notify Mr. Joe Walker and Western
Carolina University and the U.S. Army Corps of Engineers, provide public notice In accordance
with 15A NCAC 02H .0503 and provide opportunity for public hearing in accordance with 15A
NCAC 02H .0504. Any new or revised conditions shall be provided Mr. Joe Walker and
Western Carolina University in writing, shall be provided to the U.S. Army Corps of Engineers
for reference in any Permit' issued pursuant to Section 404of the Clean Water Act, and shall
also become conditions of the 404,Permit for the project.
23. Upon completion of all permitted Impacts included within the approval and any subsequent
modifications, the applicant shall be required to return a certificate of completion (available
on the DWR website https://edocs.deg. nc.00v/Forms/Certificate-of-Completion). [i5A NCAC
02H .0502(f))
24. If the property or project is sold or transferred, the new Permittee shall be given a copy of
this Certification (and written authorization if applicable) and is responsible for complying
with all conditions. 115A NCAC 02H .0501 and .05021

Western Carolina University Master Plan Improvements
DWR Project #20180612
{ individual Certification #4170
Page 8 of 8
25. This Certification neither grants nor affirms any property right, license, or privilege in any
waters, or any right of use in any waters. This Certification does not authorize any person to
interfere with the riparian rights, littoral rights, or water use rights of any other person and
this Certification does not create any prescriptive right or any right of priority regarding any
usage of water. This Certification shall not be interposed as a defense in any action respecting
the determination of riparian or littoral rights or other rights to water use. No consumptive
user is deemed by virtue of this Certification to possess any prescriptive or other right of
priority with respect to any other consumptive user regardless of the quantity of the
withdrawal or the date on which the withdrawal was Initiated or expanded.
26. This certification grants permission to the director, an authorized representative of the
Director, or DENR staff, upon the presentation of proper credentials, to enter the property
during normal business hours. [15A NCAC 02H .0502(e)]
27. Non-compliance with or violation of the conditions herein set forth by a specific project may
result in revocation ofthis General Certification for the project and may also result in criminal
and/or civil penattles.
This approval to proceed with your proposed impacts or to conduct impacts to waters as
depicted in your application shall expire upon expiration of the 404 or CAMA Permit. The
conditions in effect on the date of issuance shall remain in effect for the life of the project,
regardless of the expiration date of this Certification. [15A NCAC 02H .0507(d)(2) and 15A NCAC
02H .0506]
This the 211t day of September 2018
Karen Higgins, Supervisor
401 & Buffer Permitting Branch
KAH/s!h
WQCOD4170

Attachment B
Archaeology Interim Fieldwork Report, Paul Webb, TRC

ARCHAEOLOGICAL INVESTIGATIONS FOR THE
WESTERN CAROLINA UNIVERSITY NORTON FIELD PROJECT,
JACKSON COUNTY, NORTH CAROLINA
INTERIM FIELDWORK REPORT
North Carolina HPO ER# 18-1185
North Carolina State ARPA Permit #153
USACE Action ID 2015-00263
Submitted to:
WESTERN CAROLINA UNIVERSITY
Office of Facilities Management
3476 Old Cullowhee Road
Cullowhee, North Carolina 28723
TRC ENVIRONMENTAL CORPORATION
5 Dogwood Road
Asheville, North Carolina 28806
and
WESTERN CAROLINA UNIVERSITY
Department of Anthropology and Sociology
McKee 63B
Cullowhee, North Carolina 28723
Authored by:
Bruce D. Idol, Paul A. Webb, Brett H. Riggs, Jane M. Eastman, and Benjamin A. Steere
December 2019

INTRODUCTION
This interim field report.summarizes on -going archaeological investigations being conducted by TRC
Environmental Corporation (TRC) and the Western Carolina University (WCU) Department of
Anthropology and Sociology for the WCU Intramural Fields Project (Project) (ER 18-1185) in Cullowhee,
Jackson County, North Carolina (Figure 1). The Project is part of the WCU 2014 Master Plan Improvements
Project (U.S. Army Corps of Engineers [USACE] Action ID 2015-00263), which includes plans for the
filling of small wetland areas and a section of the adjacent Cullowhee Creek floodplain and the eventual
construction of intramural athletic fields.
This work is being conducted on behalf of the WCU Facilities Planning, Design, and Construction
Department under North Carolina State Archaeological Resources Protection Act (ARPA) Permit 153, as
originally issued on June 15, 2019 and as amended on August 19, 2019 and November 18, 2019; additional
survey of part of the ARPA Permit 153 area was also conducted under a previous permit (ARPA Permit
127, Amendment 1) (Webb 2018). The investigations conducted to date have included survey and site
evaluation as well as data recovery work at site 31 JK615, a large multi -component (primarily Mississippian
period [Pisgah phase] and Historic Cherokee [Qualla phase]) site. The fieldwork at site 31 JK615 is ongoing
and is expected to be essentially completed by early January 2020.
The initial archaeological survey and site evaluation for the Project was conducted by both TRC (Webb
2018) and WCU (Steere 2019); more recent survey and evaluation work was conducted by TRC and has
not yet been reported. The data recovery excavations at 31JK615 are also a joint effort between TRC and
WCU. TRC's work has focused on mechanized stripping, mapping, and excavation of all cultural features
except for Structure 1, an intact Middle Qualla phase winter house basin, and has been directed by Bruce
Idol with assistance from Rachael Denton. WCU faculty Dr. Jane Eastman, Dr. Brett Riggs,'and Dr. Ben
Steere are conducting excavation of Structure 1, and also have conducted photogrammetric documentation
of that structure and other structures and features (see embedded links below). Drone photography was
provided by Civil Design Concepts (CDC) of Asheville, North Carolina, and all work has been greatly
facilitated by the assistance and cooperation of Curtis Monteith and others of the WCU Office of Facilities
Management, and by Patrick Bradshaw and others of CDC. All Project work also has been coordinated
with representatives of the Office of State Archaeology (OSA) and the Eastern Band of Cherokee Indians
(EBCI) Tribal Historic. Preservation Office (THPO). Formal USACE consultation with the EBCI, the
Cherokee Nation, the United Keetoowah Band of Cherokee Indians, and the OSA has been initiated and is
ongoing.
PROJECT DESCRIPTION
The WCU Intramural Fields Project occupies a large, ca. 10-acre grassy area in the northwestern part of the
WCU campus, east of Cullowhee Creek, and west of Norton Road and the adjacent uplands (Figure 2). The
area is presently used for recreation and includes a frisbee golf course, a putting green, and a hammer throw
area. Norton Dormitory bounds the Project to the east, and much of the Project is bounded by a parking lot
to the north. The western portion of the Project is low-lying and contains several small wetlands, but the
terrain rises to the east onto a gently sloping terrace before encountering the fill associated with Norton
Dormitory. The Project is bounded by a buffer along Cullowhee Creek to the west, and by previously
developed athletic fields to the south. Plans call for the filling of existing wetlands and the deposition of fill
over the Project area, and eventually, the construction of additional formal athletic fields.
Although the initial survey work was conducted in 2018 to satisfy USACE permitting requirements (and
the consequent need to comply with Section 106 of the National Historic Preservation Act (NHPA) and its
implementing regulations, the data recovery work at site 31JK615 was begun in the belief that that site
would be outside the USACE permit area. In an on -site meeting on October 30, 2019, however, the USACE

determined that the permit area for the Project covered the entire 10-acre area. At the time of that
designation, data recovery excavations were already well in progress at site 31 JK615, and a substantial soil
stockpile (in anticipation of the eventual filling and construction of athletic fields) had been created to the'
west of the site. With the approval of the OSA and EBCI THPO, that stockpile had also been extended over
stripped areas in the southern and southwestern parts of 31JK615, where no substantial features had been
identified (Figure 3).
HISTORY AND DEPICTIONS OF THE PROJECT AREA
The WCU campus is located on land that was part of the Cherokee Nation, and was the site of a Cherokee
village known as Two Sparrows Town (Tali Tsisgwayahi). Like the surrounding area, the lands making up
the campus were ceded by treaty to the United States in 1819 (Jurgelski 2004; Riggs 1988:2-3; Royce
1887:91). That treaty contained provisions allowing any individual Cherokee head -of -family who. wished
to become a U.S. citizen to apply for a life reservation of 640 acres, and the Project is within the'reservation
of a Cherokee named Whayakah (or Grass Grow[s]), who requested such a reservation on August 9, 1819
(McLoughlin 1984:189; Riggs 1988:117). The location of Whayakah's farmstead within the 640-acre tract
is unknown, but there are no indications that it was situated within the Project.
A series of maps and photographs dating from the late 19'h through the 20'i' centuries provides information
on former conditions within and adjacent to .the Project (Webb 2018). The earliest USGS quadrangles
(USGS 1897,1907, and 1913) show no structures in the immediate Project area, and this area is not included
on a more detailed 1927 map of campus (Draper 1927). Similarly, no structures are shown within the Project
area on the 1935 planimetric map (USGS 1935) or the 1946 or 1946/78 topographic maps (USGS 1947,
1946/78). The area is shown as cultivated on a 1953 aerial photograph (Figure 4); by 1964 it had been
acquired by WCU and a sewer treatment plant had been constructed at the southeastern edge of the Project
(Figures 5 ,and 6). By 1993 the sewer treatment plant had been removed and replaced by a pond (which is
still present); much of the area to the north was being used as a golf course (Figure 7). Norton Dormitory
was constructed on fill immediately to the east of the Project in the early 2000s.
SURVEY AND EVALUATION INVESTIGATIONS
A ca. 2.2-acre area on the lower floodplain within the Project footprint was intensively surveyed by TRC
in 2018 under ARPA Permit 127, Amendment 1 in connection with the planned draining and filling of two
small wetlands (Webb 2018). That work involved the excavation and documentation of 40 shovel tests at
10- to 20-m intervals across and adjacent to the USACE permit area as then defined (see Figure 3). The
work documented varying degrees of prior ground disturbance and filling in and adjacent to the wetlands,
and no artifacts or other indications of an archaeological site were encountered.
In the Spring of 2019 (and prior to the designation of the larger USACE Permit Area), site 31JK615 was
identified on the higher terrace in the eastern part of the Project based on the presence of Qualla phase
ceramic sherds on the ground surface..That site was subsequently surveyed and evaluated (under ARPA
Permit No. 153) by the 2019 WCU archaeological field school. The fieldschool investigations encompassed
a 2.2-acre area situated above the 100-year floodplain and east of the previous TRC work, and included
excavation of 55 shovel tests on a 15-m grid (see Figure 3) and four unit blocks totaling 41 mZ. The work
defined a multicomponent site measuring ca. 100 in north -south and 60 in east -west, encompassing most
of the higher terrace area within the Project. Thirty-three of the 55 shovel tests produced precontact to
contact period artifacts, and the test unit blocks alone generated totals of 1,642 ceramic and 1,358 lithic
artifacts, as well as apparent cultural features intruding the B horizon subsoil (Steere 2019). Diagnostic
artifacts recovered were primarily Mississippian (Pisgah series) and Qualla phase ceramics. As a result of
the investigation, site 31JK615 was recommended eligible for the NRHP under Criterion D (Steere 2019),
and planning began for the further (data recovery) investigation of the site prior to filling.
fA

Following the October 2019 USACE designation of the 10-acre permit area, the remainder of the 10-acre
tract (all on the lower floodplain) was surveyed by TRC in November 2019. That work included excavation
of over 100 additional shovel tests and identified three additional small sites (site numbers pending), each
represented by from one to four precontact ceramic and/or lithic artifacts. Those sites will be recommended
not eligible for the NRHP in a forthcoming report.
DATA RECOVERY EXCAVATIONS AT SITE 31JK615
Following the WCU Field School investigation, data recovery fieldwork began at site 31JK615 on August
26, 2019 under ARPA Permit 153, Amendment 1. These investigations are ongoing and have include
mechanized stripping, mapping, and feature excavation. These investigations have identified multiple
structures and features associated with the Pisgah and Qualla phase occupations of the site, in addition to
artifacts representing the Middle Archaic, Late Archaic, and Middle Woodland periods. .
Results of Mechanized Stripping
Initially, a trackhoe equipped with a flat -bladed bucket was used to remove topsoil from a ca. 4,598 square
meter (1.14 acre) area at 31 JK615, representing essentially all of the defined site area (see Figure 3). (The
remaining area that produced artifacts during shovel testing is low-lying, and those artifacts are believed to
represent downslope movement due to agriculture.) This stripping encompassed almost all of the higher
terrace area west of Norton Dormitory and south of the parking lot, north of the pond and east of the
wetlands. An existing sewer line corridor (running northeast -southwest across the southern part of the
investigated area) was excluded from the investigation due to the prior disturbance, although some stripping
was conducted to the south of the sewer line.
The stripping generally encountered a simple A/B horizon soil sequence consisting of a dark brown
plowzone overlying a strong brown to red Bt horizon subsoil. The Bt horizon varied in texture and
character, and was excessively pebbly in some areas (especially west and northwest of Structure 1, see
below). The area south of the sewer line corridor was found to be highly disturbed from past grading
activities, and no cultural features were identified in that area. The well drained portion of the terrace was
bounded to the west by hydric soils associated with nearby wetland areas. A buried A horizon (Ab horizon)
was encountered along the boundary of the terrace and the adjacent floodplain. Composed of black to very
dark brown silt loam, this was of varied thickness (generally between five and 30 cm) and.was underlain
by gray hydric soils, often flecked with iron oxide concretions. This Ab horizon deposit appears (at least in
part) to represent a shallow swale that arcs around the higher terrace. This swale afforded artifacts in the
area some protection from plowing, as a few large Qualla series sherds were encountered along its eastern
edge, and it appears to have been a reservoir for historic period colluvium originating from the higher
terrace to the east. This area had also been ditched historically, as discussed below.
On the higher part of the terrace, the stripping encountered three Pisgah phase structures associated with a
nucleated and palisaded settlement, seven Qualla phase structure patterns and other linear post patterns and
dispersed posts, and associated pit features, including six probable human graves (Tables 1 and 2; Figures
8=10). (The probable graves were identified based on pit shape and fill characteristics; the pits have not
been investigated further, and no human remains or funerary objects were observed.)

Table 1. Structure Patterns Identified at 31JK615 (as of November 30, 2019).
Structure Component Type Comments
.1 Contact period Cherokee (Middle winter house burned structure; intact floor
Qualla phase)
2 Mississippian period (Pisgah phase) house large flexed pole; central
3 Mississippian period (Pisgah phase)
4 Contact period Cherokee (Middle
Qualla phase)
5 Contact period Cherokee (Middle
Qualla phase)
6 Contact period Cherokee (Middle
Qualla phase)
7 Mississippian period (Pisgah phase)
hearth; two graves associated
house small flexed pole; central hearth
winter house heavily truncated; central
support posts, partial walls
summer house large rectangular
summer house large rectangular
public building ? very large rectangular with
rounded ends
8 Contact period Cherokee (Middle winter house remnant central hearth; central
Qualla phase) supports; intact outer wall
9 Contact period Cherokee (Middle storehouse rectangular
Qualla phase) '
10 Contact period Cherokee (Middle storehouse rectangular
Qualla phase)
Table 2. Pit Features Identified at 31JK615 (as of November 30.2019).
Feature
Northing
Easting
Type
Component
Comments
188
133.32
292.93
hearth
Pisgah phase
Structure 3
190
144.48
292.82
grave
Pisgah phase?
inside Structure 2
470
147.88
270.92
pit
Pisgah phase?
isolated pit and
posthole
471
148.45
271.25
pit
Middle Qualla phase
extremely truncated
503
155.34
264.48
pit
Middle Qualla phase
Midden-filled
537
143.95
294.67
hearth
Pisgah phase
Structure 2
625
170.27
287.14
smudge pit?
Unknown
wood charcoal only
683
166.08
289.42
grave
Unknown
830
160.60
283.36
pit
Middle Qualla phase
inside Structure 5
1480
112.70
294.71
pit
Pisgah phase
few artifacts
1481
111.86
296.39
pit
Pisgah phase
few artifacts
1484
110.88
292.25
pit
Pisgah phase
few artifacts
1485
110.10
293.28
pit
Pisgah phase
few artifacts
1499
144.10
291.91
grave
Pisgah phase?
inside Structure 2
1620
103.04
299.43
hearth
Qualla phase
Structure 8
1736
257.42
257.42
pit
Middle Qualla phase
1737
156.13
256.31
pit
Middle Qualla phase
1739
160.66
255.74
pit?
Middle Woodland?
ambiguous pit; two
Connestee? sherds
1742
177.82
286.52
grave
Unknown
1743
178.65
283.81
grave
Unknown
1744
180.27
279.33
grave
Unknown
1745
NA
NA
ditch
historic Euro-American
ditch
1874
173.55
254.54
pit
Middle Qualla phase
1893
157.72
259.11
pit
Middle Qualla phase
1900 146.16 256.81 pit? Middle Qualla phase? ambiguous pit,
possibly non -cultural
4

Pisgah Phase Structures, Palisade, and Pits
Three Pisgah phase structure patterns were identified, all apparently enclosed within a palisade line that
extends outside the stripped area toward Norton Dormitory to the east.
Structure 2. Structure 2 is a large, Pisgah phase structure with a central hearth remnant, defined by a nearly
square outer wall and interior support posts (Figure 11; https:Hsketchfab.com/3d-models/3lik615-piseah-
house-a-451937868adb434Oe015cddl2bb3fibf; see Figures 8-10). The structure measures approximately
7.6 by 7.0 m; the size and orientation of postholes indicates that it was of flexed pole construction. Two
potential graves are situated within the footprint of this structure and are believed to be contemporaneous.
This structure appears to overlap an additional structure in its northeastern quadrant, but that potential
structure has not been totally exposed and has not been assigned a number.
Structure 3. Structure 3 is a nearly square, Pisgah phase structure with a central hearth remnant situated a
short distance south of Structure 2 (Figure 12, httr)s:Hsketchfab.com/3d-models/3Iik615-niseah-house-b-
8bebf80742104cOc9af316lcic9effb3 see Figures 8-10). Smaller than Structure 2, Structure 3 was of
similar construction, but was built on a slightly different alignment. It measures approximately 4.5 by 4.5
In.
Structure 7. Structure 7 is a very large, rectangular structure with distinctly rounded ends (Figure 13,
https://sketch£ab.com/3d-models/3 lik615-nis¢ah-public-structure-a7193c5725e04f7c8cd25958e 17d7327;
see Figures 8-10). The structure was defined by a single exterior wall line and three central, interior support
posts; it measures approximately 11.4 by 7.6 m. A similar structure was excavated at the Ravensford sites
in Swain county (Benyshek and Webb 2018), where associated artifacts and radiocarbon dates indicate an
Early Pisgah phase affiliation. Given its size, Structure 7 likely served as a public building.
Palisade. A prominent post line that arcs around the Pisgah phase settlement is interpreted as a palisade line
(see Figures 8-10). The palisade line extends outside the excavated area beneath fill to the northeast and
southeast, suggesting that an unknown part of the Pisgah village is situated beneath the fill west of Norton
Dormitory as well as the building itself. There are only four well -studied Pisgah phase sites with clearly
identifiable palisades in southwestern North Carolina: the Warren Wilson (31BN12), Garden Creek
(31HW7), Cane River (31YC91), and Cullowhee Valley School (31JK) sites (Schubert and Horsley 2015).
Pisgah Phase (Non -Grave) Pits. At least four pit features are attributed to the Pisgah phase occupation of
31JK615; all were located just southwest of Structure 7 (Figure 13, see Figures 8-10 and Table 2). These
were large, flat-bottomed facilities (possible storage or borrow pits) that contained very few artifacts. One
of these overlapped the palisade line (see below), and although the order of superimposition remains
uncertain, there was no evidence that the palisade post intruded the pit, suggesting that the palisade predates
the pit. One outlying small pit (situated outside of the palisade) produced Pisgah series sherds, but the
nature of this pit (and its relationship to an underlying posthole) remains ambiguous pending analysis.
Qualla Phase Structures and Pits
The seven Qualls phase structure patterns include three winter houses, two summer houses, and two storage
buildings (granaries or corn cribs).
Structure 1. Structure I is a precontact to Historic Cherokee (Middle to Late Middle Qualla phase, ca. A.D.
1650-1700) burned winter house with a partially intact and substantially rich floor midden (Figures 14 and
15, see Figures 8-10). The precise configuration of the structure (or overlapping structures) has not yet
been determined due to the presence of the associated floor midden and the ongoing excavations, but the
structure appears typical of Middle to Late Qualls phase architecture; it measures roughly seven by seven

meters and includes remnant entryway trenches. WCU is currently excavating and documenting the floor
deposits associated with this structure in 1 x 1 m units, and excavation of the associated postholes, hearth,
and any sub -floor (non -grave) pits will be undertaken in the coming weeks.
Structure 4. Structure 4 is a remnant Qualla phase winter house located a short distance northwest of
Structure l (Figures 8-10). It is represented by a partial posthole pattern that includes four central support
postholes, some additional potential interior patterning, and portions of a circular to near -circular outer
wall. Plowing has obliterated all associated floor deposits, including any trace of the central hearth. This
structure presumably predates Structure 1.
Structure 5. Structure 5 is a rectangular Qualla phase summer -type house located north of Structure 1 and
oriented east -west on its long axis; the associated post pattern suggests some interior segmentation,
including an attached portico on the western end (Figure 16, httos://sketchfab.com/3d-models/31ik615-
summer-house-b-cc3cbOb43c7f4elab8el25f1ccf65361; see Figures 8-10). IT measures about 6.8 by 3.8
m. Many of the associated postholes contained midden rich fill and a small, midden-filled pit (Feature 830)
was situated within the structure.
Structure 6. Structure 6 is a second rectangular Qualls phase summer house located immediately south of
Structure 1 and oriented east -west (Figure 17, httos://sketchfab.com/3d-models/3I ik615-summer-house-a-
Odc26f9830844a58bca277eb6fb3a637; see Figures 8-10). Structure 6 is similar in orientation to Structure
5, but is closer to the nearby Structure 1 winter house; it measures about 5.0 by 4.0 m. Posthole patterning
suggests that it had an attached portico on the western end, possibly used for external storage.
Structure 8. Structure 8 is an outlying Qualls phase winter house and is the southern -most house found
(Figure 18, https:Hsketchfab.com/3d-models/31ik6l5-(ivalla-asi-9b6bblbe69lf4cdaa4db6964cbe6bal2;
see Figures 8-10). It is represented by central support posts surrounding a remnant hearth and is
characterized by a circular to near -circular outer wall. There is no evidence of an associated summer
structure, although it is possible that one is situated to the north, beneath fill. Alternatively, such evidence
may have been obliterated during construction of the sewer line a short distance to the south. This structure
may overlap an earlier Pisgah structure.
Structure 9. This is a small, Qualla phase storehouse (granary or corn crib) situated west of the Structure 5
summer house (Figure 19; see Figures 8-10). It is a rectangular outbuilding represented by eight wall
postholes and oriented with its long axis perpendicular to that of Structure 5; it measures approximately 4.7
by 2.5 m. The associated postholes are extremely robust, and many contain midden rich fill.
Structure 10. This is another Qualla phase auxiliary structure (granary or corn crib), situated east of the
Structure 5 summer house (Figure 20; see Figures 8-10). It is a rectangular outbuilding represented by eight
defining deep wall postholes, and its long axis is parallel to that of Structure 5. It measures approximately
4.6 by 3.7 m. Some of the associated postholes contain midden rich fill.
Oualla Phase (Non -Grave) Pits. The stripping also revealed at least seven non -grave pit features attributed
to the Cherokee occupation (see Figures 8-10 and Table 2). These were generally located in the area west
of the Structure 1 winter house to the edge of the swale. These contained varied types of fill ranging from
that obtained from general (non-midden) contexts to house floor sweepings. One small midden-filled pit
was encountered inside one of the summer structures (Structure 5).
Other Post Patterns. Four shorter (partial) linear patterns were also identified; two of these were located
near Qualla phase Structure 8, one is located near Qualla phase Structure 5, and one was situated near
Pisgah phase Structure 3 (see Figures 8-10). These are all of unknown component affiliation pending

analysis, but appear associated with the Qualla phase occupation. These appear to represent partial
enclosures or screens and do not appear to represent any additional palisade lines.
Probable Human Graves
Six probable human graves have been identified based on pit shape and fill characteristics (see Figures 8
and 9); no human remains or human funerary objects were observed. Two of the probable graves are situated
in the northwestern portion of Structure 2 (a Pisgah phase house); these are adjacent to one another and are
thought to be contemporary with that domestic structure. Four additional potential graves are dispersed in
the area north of the identified Cherokee structures, near the parking lot. Their association is unclear. All
of the potential graves have been left in place and temporarily covered pending the completion of
consultation concerning how best to preserve them in place.
Additional Precontact Components
Other precontact cultural components at 31JK615 are represented by a few diagnostic artifacts from
ambiguous, mixed, or unsecure component contexts. A Middle Woodland (Connestee phase) component is
represented by a few artifacts from stripped plowzone contexts, and possibly by a small number of sherds
from an ambiguous pit feature.(Feature 1739); small numbers of Late Woodland (Napier) ceramics were
also recovered A Late Archaic component is represented by a soapstone vessel sherd and a few Savannah
River stemmed projectile points. A Middle Archaic component is represented by at least one Morrow
Mountain stemmed projectile point. Other projectile points and bifaces are more ambiguous but appear to
represent a continuum of Middle Archaic to Woodland manufacture: No prolonged Archaic or Woodland
period habitation is indicated by the limited evidence.
Historic Euro-American Ditch
A linear ditch was encountered below the swale deposit (it was not discernable at the surface of the swale
deposit) (Figure 21; see Figures 8 and 9). Extending north -south for over 85 in, it was slightly over one
meter wide, exhibited clear edges, and contained hydric soils. Two mechanized trenches were cut across
this ditch feature; those excavations did not produce artifacts, although stripping and metal detecting
encountered a few late 19th to 20th century artifacts (e.g., a partial muleshoe, a partial horseshoe, and a
shotgun shell base) as well as earlier materials (Archaic debitage and Qualla series sherds). Another trench
was cut into a large, mottled feature that was intrusive into the ditch, which encountered a cinderblock in
otherwise sterile fill. The ditch presumably was a drainage ditch along the edge of the lower floodplain,
possibly along a field boundary or field road. The function of the intrusive feature is unknown, but it could
be a horse or cow grave. Interestingly, both features were totally obscured by at least some of the overlying
"swale" sediments, which presumably represent a combination of overbank deposits and sediment that
moved downslope from the higher terrace.
Although a few late 19th to 20th century historic period artifacts were found elsewhere on the site, there are
no indications of past non-agricultural (or golf -related) uses of the landform.
PUBLIC EDUCATION / PRESENTATIONS / SITE VISITS
In addition to its research value, the work at 31JK615 an excellent for public education regarding the
Cherokee presence and archaeology of this part of western North Carolina. Many individuals and groups
have visited the excavations at 31JK615, and the work has also been the subject of several presentations.
In addition to official representatives of the OSA, EBCI THPO, and USACE and faculty or staff from
Appalachian State University, the University of Tennessee, and the National Forests in North Carolina,
visitors have included:

• Swain County Schools Cultural Summer Camp: students toured the site and participated in test
unit excavation (included EBCI primary school students)
• Catamount School (Jackson County Schools/WCU), sixth and eighth grade classes toured the site
• Exploring Joara Foundation: archaeological summer camp for middle -school students toured the
site and participate in test unit excavation
• Mountain Heritage Center Summer Camp: elementary school students toured the site and
participated in test unit excavation
• Swain County High School: two US History classes toured the site (including EBCI students)
• Oconaluftee Job Corps Civilian Conservation Center: Larry Blythe, Training Instructor, and
students toured the site
• EBCI New Kituwah Academy teachers toured the site
• Rooted in the Mountains Symposium: over 75 students, faculty, community members, and
visiting scholars were given a walking tour of the site
• Cherokee Friends from Museum of the Cherokee Indians, Cherokee
• WCU class visits:
• Anthropology 110 (Origins of Civilization)
• Anthropology 120 (Comparative Cultural Systems)
• First Year Seminar (Geology, Landscapes, and the Human Psyche)
• Anthropology 461 (Indians of North America)
• WCU Student Television Production Class: two students filmed excavation of Structure 1 and
interviewed WCU faculty about excavations
• . Presentations were also made to:
• Cherokee Language Consortium (visiting elders from Cherokee Nation, Oklahoma)
• WCU Board of Trustees
• WCU Board of Visitors
• WCU Student Affairs Leadership
• Cherokee Archaeological Symposium (Cherokee, North Carolina)
• Southeastern Archaeological Conference (Jackson, Mississippi)
Numerous WCU students also have participated in the excavations, including interns Austin Peters and
Crandall Close, multiple students from Dr. Eastman's ANTH 110 class working under honors contracts;
Dr. Riggs' ANTH 441 class members, and Federal work study students Daniel Byers, Alyssa Priest, and
Victoria Lemell: Press coverage has been provided by WCU Reporter, the Sylva Herald and Blue Ridge
Public Radio.
8

SUMMARY AND UPCOMING WORK
In summary, multiple stages of archaeological investigations have been completed or are in progress for
the WCU Norton Field Project. Survey and evaluation fieldwork has been completed and partially reported
(Steere 2019; Webb 2018); a report on the final stages of that work is in preparation. Four sites were
identified during that work; three will be recommended not eligible for the NRHP under all four criteria,
while the fourth (31JK615) was recommended eligible for the NRHP under Criterion D (Steere 2019).
Large scale data recovery excavations began at site 31JK615 in August 2019. That work is nearing
completion and has revealed substantial Pisgah and Qualla phase settlements, including multiple structure
patterns and an intact Cherokee winter house basin (Structure 1).
Several stages of fieldwork remain to be completed at site 31 JK615:
WCU faculty, assisted by students and TRC staff, are presently excavating the fallen roof and
wall materials and underlying floor deposits in Structure 1. This work includes detailed
photogrammetric documentation and promises to provide substantial information concerning the
organization of activities within this structure. Once the floor deposits are removed, the
underlying subsoil will be cleaned, and the posts, along with any non -grave pit features that are
present, will be mapped and excavated. That work is anticipated to be completed by January 15,
2020.
As discussed above and shown in Figure 10, stockpiling of fill is presently underway in the area
west of the excavated site, and the OSA and EBCI THPO have permitted filling over of a
stripped area at the southwestern comer of the excavation (as well as an area south of the sewer
line) to facilitate this process.. Via this report, we are now requesting permission for fill to be
deposited over an additional area at the western edge of the site (west of Structures 1, 4, and 9) to
facilitate the continued work on the overall construction Project (Figure 22). This fill would cover
over the remaining part of the historic ditch, along with a few excavated posts and pit features,
but would not obscure any structure patterns.
• When permitted by the consulting parties, TRC and WCU plan to conduct limited additional
stripping to remove three small unexcavated areas along the eastern edge of the stripped area and
map and excavate posts and non -grave features; because of the topography and depth of fill in
that area, this work cannot be conducted until all parties agree that it is acceptable to deposit fill
over the Structures 2 and 3 areas.
When instructed by the consulting parties, TRC and WCU will implement necessary procedures
to ensure that the probable human graves can be preserved in place. Although the details of these
procedures remain to be established, we anticipate that the graves will likely be preserved
beneath successive layers of filter fabric, steel rebar (to deter intrusion and allow the locations to
be identified with a metal detector), sterile sand (to facilitate recognition), and additional sterile
soil.
Initial laboratory processing is underway at the WCU laboratory, and WCU and TRC anticipate authoring
a joint report on all stages of the Norton Field Project. Due to the time necessary to complete reporting on
a data recovery Project of this size and complexity, we request that the agencies and consulting parties agree
to authorize the remaining construction activities for the Project once the fieldwork at 31JK615 is complete,
a Management Summary has been submitted and reviewed, and the necessary steps taken to protect the
human graves.
0

REFERENCES
Benyshek, Tasha, and Paul A. Webb .
2018 Archaeological Data Recovery Excavations at the Ravensford Site (31SW78 and 31SW136), Swain
County, North Carolina, Volume 1: Archaic, Woodland, Mississippian, and Historic Cherokee Components.
TRC Environmental Corporation, Chapel Hill.
Draper, E.S.
1927 General Plan for Development of Campus of Cullowhee State Normal School, Cullowhee, North
Carolina. E.S. Draper, Landscape Architect & Engineers, Charlotte, North Carolina and Atlanta, Georgia.
Jurgelski, William Martin
2004 A New Plow in Old Ground: Cherokees, Whites, and Land in Western North Carolina, A.D. 1819-1829.
Unpublished dissertation in Anthropology, University of Georgia, Athens.
McLoughlin, William G.
1984 Experiment in Cherokee Citizenship, 1817-1829. In The. Cherokee Ghost Dance, Essays on the
Southeastern Indians 1789-1861, by William G. McLoughlin with Walter H. Conser, Jr., and Virginia Duffy
McLoughlin, pp. 153-191. Mercer University Press.
Riggs, Brett H.
1988 An Historical and Archaeological Reconnaissance of Citizen Cherokee Reservations in Macon, Swain,
and Jackson Counties, North Carolina. Submitted to the North Carolina Division of Archives and History,
Raleigh.
Royce, C.C.
1887 The Cherokee Nation of Indians. In Fifth Annual Report of the Bureau ofAmerican Ethnology,
Smithsonian Institution, Washington.
Schubert, Ashley,.and Timothy Horsley
2015 Determining Village Extent and Layout Utilizing Geophysical Survey and Excavation at the
Mississippian Site of Cane River, North Carolina. Paper Presented at the 801 Annual Meeting of the Society
for American Archaeology, San Francisco, California.
Steere, Ben
2019 Preliminary Field Report, Archaeological Survey and Testing by the Western Carolina University
Archaeology Field School for the proposed Norton Intramural Field in Cullowhee, Jackson County, North
Carolina. Letter to Curtis Monteith, WCU Facilities Management, Cullowhee.
United States Geological Survey (USGS)
1886 Cowee, North Carolina. 1:125,000 scale topographic map.
1897 Cowee, North Carolina. 1:125,000 scale topographic map.
1907 Cowee, North Carolina. 1:125,000 scale topographic map.
1913 Cowee, North Carolina. 1:125,000 scale topographic map.
1935 Cullowhee, North Carolina. 1:24,000 scale planimetric map.
1946 Sylva South, North Carolina. 1:24,000 scale topographic map.
1946/78 Sylva South, North Carolina. 1:24,000 scale topographic map. Photorevised 1978.
Webb, Paul A.
2018 Archaeological Survey and Testing for the Proposed Western Carolina University STEM Building
Project, Jackson County, North Carolina. Addendum 1: Survey of Portions of the Intramural Fields for the
WCU 2014 Master Plan Improvements Project, North Carolina State ARPA Permit #127. Submitted to Civil
Design Concepts, P.A., Asheville. TRC Environmental Corporation, Chapel Hill.
10

• 4 �j•
� t
tZ11 t
t
A'
� c
il% t.. watlrMs 1
;1
Negative Shovel Test n
• Positive Precontact Shovel Test
Stripped Area
ODrainPond
® Existing Stockpile
" Proposed Stockpile i
USACE Survey Area (2018)
O USACE Permit Area (2019)
Contour (2 ft) i
Figure 3. Existing conditions in Project Area as of November 11, 2019.
13

ty
. Y e
�
c
Aerial Photograph 1953
WFeet
Jackson County, North Carolina
14
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8

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50+00
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1
H,gheor Planning Map 1964
a N
oun
ai WE
21,11
Ncm�u 8
Jackson County, North Carolina
Figure 5. The Norton Field Permit Area as shown on a 1964 highway planning map.
15

l' M'
* , PROJECT, V �-
i
AREA
• � .'fir ^y ..fir i
. P
Ak \q
1
a
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Aerial Photograph 1975
ti
o too
Feel W E
201
Mewn a
Jackson County, North Carolina
Figure 6. The Norton Field Permit Area as shown on a 1975 aerial photograph.
16

EY
0
9
•
datum
post feature
+
potential grave
hearth feature
pit feature
O
Stripped Area
Contour (2 ft)
10 20 30
Meters
I
Figure 8. Stripped areas, structures, and other subsurface features at 31JK615 as of November 11,
2019. (Structure 1 is situated in blank area in center of map and is not shown.)
18

wcilanA ��P�-� .'O.• f���
i
� onJd•;�, /fit
OP
kPallsd,
MIN
,qt
• datum
post feature
+ potential grave i
tIF hearth feature
pit feature •., ',.
Stripped Area
Contour (2 fl)
0 10 20 30
-NiiiRMeters
1
e
Figure 9. Stripped areas, structures, and other subsurface features at 31JK615 (annotated).
[F
t

-
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Ir
14
40
Figure 10. Aerial (drone) photograph of 31JK615 excavations on November 22, 2019.
20

Figure 11. Structure 2. South at top.
21

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s
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1 l^�nr l ; >iiunurk, v\ i h 11., 11ndr U i�,'it I m: ,.d], c ,]if pi'. ,1, 1 I I h') 1„,11 - I,I tu1).

Figure 14. Structure 1, with earlier palisade (bottom). Facing west.
24

Figure 15. Fired clay, charred beams, and artifacts in Structure 1.
25

Figure 16. Structure 5. South to top.
26

Figure 17. Structure 6. South to top.
Oil

Figure 18. Structure 8, with earlier palisade (bottom) and possible Pisgah structure. South to top.
�
l
- a
,
I ) 1

I igurc 20. Siructurc 10. South to top.
29

Figure 21. Historic ditch (Feature 1745), facing north.
30

• datum
• post feature
i1F hearth feature
0 pit feature
OCurrent Stripped Area
® Current Filled Area
Proposed Fill Area
Contour (2 ft)
0 10 20 30
Meters
N
,t r
.. •�. Propnud
Stripping
�
Figure 22. Locations of additional areas at 31JK615 proposed for filling and mechanized stripping.
31

Attachment C
NC WAM forms

NC WAM FIELD ASSESSMENT FORM
Accompanies user manual version o.0
USACE AID #
NCDWR#
Project Name
WCU Master Plan Improvements
Date of Evaluation
October 30, 2019
Applicant/Owner Name
WCU: Attn Joe Walker
Wetland Site Name
W1
Wetland Type
Bottomland Hardwood Forest
Assessor Name/Organization
CEC
Level III Ecoregion
Blue Ridge Mountains
Nearest Named Water Body
Cullowhee Creek
River Basin
Little Tennessee
USGS 8-Digit Catalogue Unit
06010203
County
Jackson
NCDWR Region
Asheville
® Yes ❑ No
Precipitation within 48 hrs?
Latitude/Lonaitude�(deci-decrees)
35.31556:-83.18790
Evidence of stressors affecting the assessment area (may not be within the assessment area)
Please circle and/or make note on the last page if evidence of stressors is apparent. Consider departure from reference, if appropriate, in
recent past (for instance, within 10 years). Noteworthy stressors include, but are not limited to the following.
Hydrological modifications (examples: ditches, dams, beaver dams, dikes, berms, ponds, etc.)
• Surface and sub -surface discharges into the wetland (examples: discharges containing obvious pollutants, presence of nearby septic
tanks, underground storage tanks (USTs), hog lagoons, etc.)
• Signs of vegetation stress (examples: vegetation mortality, insect damage, disease, storm damage, salt intrusion, etc.)
• Habitat/plant community alteration (examples: mowing, clear -cutting, exotics, etc.)
Is the assessment area intensively managed? ® Yes ❑ No
Regulatory Considerations - Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑ Anadromous fish
® Federally protected species or State endangered or threatened species
❑ NCDWR riparian buffer rule in effect
❑ Abuts a Primary Nursery Area (PNA)
❑ Publicly owned property
❑ N.C. Division of Coastal Management Area of Environmental Concern (AEC) (including buffer)
® Abuts a stream with a NCDWQ classification of`SA or supplemental classifications of HQM ORW, or Trout
❑ Designated NCNHP reference community
❑ Abuts a 303(d)-listed stream or a tributary to a 303(d)-listed stream
What type of natural stream is associated with the wetland, if any? (check all that apply)
❑ Blackwater
® Brownwater
❑ Tidal (if tidal, check one of the following boxes) ❑ Lunar ❑ Wind ❑ Both
Is the assessment area on a coastal island? ❑ Yes - ® No
Is the assessment area's surface water storage capacity or duration substantially altered by beaver? ❑ Yes ® No
Does the assessment area experience overbank
1. Ground Surface Condition/Vegetation Condition — assessment area condition metric
Yes ❑ No
Check a box in each column. Consider alteration to the ground surface (GS) in the assessment area and vegetation structure (VS) in the
assessment area. Compare to reference wetland if applicable (see User Manual). If a reference is not applicable, then rate the assessment
area based on evidence an effect.
GS VS
®A ®A Not severely altered
❑B ❑B Severely altered over a majority of the assessment area (ground surface alteration examples: vehicle tracks, excessive
sedimentation, fire -plow lanes, skidder tracks, bedding, fill, soil compaction, obvious pollutants) (vegetation structure
alteration examples: mechanical disturbance, herbicides, salt intrusion [where appropriate], exotic species, grazing, less
diversity [if appropriate], hydrologic alteration)
2. Surface and Sub -Surface Storage Capacity and Duration — assessment area condition metric
Check a box in each column. Consider surface storage capacity and duration (Surf) and sub -surface storage capacity and duration (Sub).
Consider both increase and decrease in hydrology. A ditch 5 1 foot deep is considered to affect surface water only, while a ditch > 1 foot
deep is expected to affect both surface and sub -surface water. Consider tidal flooding regime, if applicable.
Surf Sub
❑A ❑A Water storage capacity and duration are not altered.
®B ®B Water storage capacity or duration are altered, but not substantially (typically, not sufficient to change vegetation).
❑C ❑C Water storage capacity or duration are substantially altered (typically, alteration sufficient to result in vegetation change)
(examples: draining, flooding, soil compaction, filling, excessive sedimentation, underground utility lines).
3. Water Storage/Surface Relief — assessment area/wetland type condition metric (skip for all marshes)
Check a box in each column. Select the appropriate storage for the assessment area (AA) and the wetland type (WT).
AA WT
3a. ®A ®A Majority of wetland with depressions able to pond water > 1 deep
❑B . ❑B Majority of wetland with depressions able to pond water 6 inches to 1 foot deep
❑C ❑C Majority of wetland with depressions able to pond water 3 to 6 inches deep
❑D ❑D Depressions able to pond water < 3 inches deep
3b. ®A Evidence that maximum depth of inundation is greater than 2 feet
❑B Evidence that maximum depth of inundation is between 1 and 2 feet .
❑C Evidence that maximum depth of inundation is less than 1 foot

4. Soil Texture/Structure — assessment area condition metric (skip for all marshes)
Check a box from each of the three soil property groups below. Dig soil profile in the dominant assessment area landscape feature.
Make soil observations within the top 12 inches. Use most recent National Technical Committee for Hydric Soils guidance for regional
indicators.
4a. ❑A Sandy soil
®B Loamy or clayey soils exhibiting redoximorphic features (concentrations, depletions, or rhizospheres)
❑C Loamy or clayey soils not exhibiting redoximorphic features
❑D Loamy or clayey gleyed soil
❑E Histosol or histic epipedon
4b. ®A . Soil ribbon < 1 inch
❑B Soil ribbon z 1 inch
4c. ❑A No peat or muck presence
®B A peat or muck presence
5. Discharge into Wetland — opportunity metric
Check a box in each column. Consider surface pollutants or discharges (Surf)and sub -surface pollutants or discharges (Sub). Examples
of sub -surface discharges include presence of nearby septic tank, underground storage tank (UST), etc.
Surf Sub
❑A ❑A Little or no evidence of pollutants or discharges entering the assessment area
®B ®B Noticeable evidence of pollutants or discharges entering the wetland and stressing, but not overwhelming the
treatment capacity of the assessment area
❑C ❑C Noticeable evidence of pollutants or discharges (pathogen, particulate, or soluble) entering the assessment area and
potentially overwhelming the treatment capacity of the wetland (water discoloration, dead vegetation, excessive
sedimentation, odor)
6. Land Use — opportunity metric (skip for non -riparian wetlands)
Check all that apply (at least one box in each column). Evaluation involves a GIS effort with field adjustment. Consider sources draining
to assessment area within entire upstream watershed (WS), within 5 miles and within the watershed draining to the assessment area (5M),
and within 2 miles and within the watershed draining to the assessment area (2M).
WS
5M
2M
❑A
❑A
®A
> 10% impervious surfaces
❑B
❑B
❑B
Confined animal operations (or other local, concentrated source of pollutants
❑C
❑C
❑C
z 20% coverage of pasture
❑D
❑D
❑D
z 20% coverage of agricultural land (regularly plowed land)
®E
®E
®E
z 20% coverage of maintained grass/herb
®F
®F
®F
z 20% coverage of clear-cut land
❑G
❑G
❑G
Little or no opportunity to improve water quality. Lack of opportunity may result from little or no disturbance in
the watershed or hydrologic alterations that prevent drainage and/or overbank flow from affecting the
assessment area.
7. Wetland Acting as Vegetated Buffer— assessment area/wetland complex condition metric (skip for non -riparian wetlands)
7a. Is assessment area within 50 feet of a tributary or other open water?
®Yes []No If Yes, continue to 7b. If No, skip to Metric 8.
Wetland buffer need only be present on one side of the water body. Make buffer judgment based on the average width of wetland.
Record a note if a portion of the buffer has been removed or disturbed.
7b. How much of the first 50 feet from the bank is wetland? (Wetland buffer need only be present on one side of the .water body. Make
buffer judgment based on the average width of wetland. Record a note if a portion of the buffer has been removed or disturbed.)
❑A z 50 feet
❑B From 30 to < 50 feet
❑C From 15 to < 30 feet
®D From 5 to < 15 feet
❑E < 5 feet or buffer bypassed by ditches
7c. Tributary width. If the tributary is anastomosed, combine widths of channels/braids for a total width.
❑515-feet wide ®> 15-feet wide ❑ Other open water (no tributary present)
7d. Do roots of assessment area vegetation extend into the bank of the tributary/open water?
®Yes ❑No
7e. Is stream or other open water sheltered or exposed?
®Sheltered — adjacent open water with width < 2500 feet and no regular boat traffic.
❑Exposed — adjacent open water with width a 2500 feet or regular boat traffic.
8. Wetland Width at the Assessment Area —wetland type/wetland complex condition metric (evaluate WT for all marshes and
Estuarine Woody Wetland only; evaluate WC for Bottomland Hardwood Forest, Headwater Forest, and Riverine Swamp Forest
only)
Check a box in each column for riverine wetlands only. Select the average width for the wetland type at the assessment area (WT) and
the wetland complex at the assessment area (WC). See User Manual for WT and WC boundaries.
WT WC
❑A ❑A i' 100 feet
❑B ❑B From 80 to < 100 feet
❑C ❑C From 50 to < 80 feet
❑D ❑D From 40 to < 50 feet
❑E ❑E From 30 to < 40 feet
❑F ❑F From 15 to < 30 feet
®G ®G From 5 to < 15 feet
❑H ❑H < 5 feet

9. Inundation Duration — assessment area condition metric (skip for non -riparian wetlands)
Answer for assessment area dominant landform.
❑A Evidence of short -duration inundation (< 7 consecutive days)
❑B Evidence of saturation, without evidence of inundation
®C Evidence of long -duration inundation or very long -duration inundation (7 to 30 consecutive days or more)
10. Indicators of Deposition — assessment area condition metric (skip for non -riparian wetlands and all marshes)
Consider recent deposition only (no plant growth since deposition).
❑A Sediment deposition is not excessive, but at approximately natural levels.
®B Sediment deposition is excessive, but not overwhelming the wetland.
❑C Sediment deposition is excessive and is overwhelming the wetland.
11. Wetland Size —wetland type/wetland complex condition metric
Check a box in each column. Involves a GIS effort with field adjustment. This metric evaluates three aspects of the wetland area: the
size of the wetland type (WT), the size of the wetland complex (WC), and the size of the forested wetland (FW) (if applicable, see User
Manual). See the User Manual for boundaries of these evaluation areas.' If assessment area is clear-cut, select "K" for the FW column.
WT
WC
FW (if applicable)
❑A
❑A
❑A
z 500 acres
❑B
❑B
❑B
From 100 to < 500 acres
❑C
❑C
❑C
From 50 to < 100 acres
❑D
❑D
❑D
From 25 to < 50 acres
❑E
❑E
❑E
From 10 to < 25 acres
❑F
❑F
❑F
From 5 to < 10 acres
❑G
❑G
❑G
From 1 to < 5 acres
❑H
❑H
❑H
From 0.5 to < 1 acre
01
01
❑I
From 0.1 to < 0.5 acre
❑J
❑J
®J
From 0.01 to < 0.1 acre
❑K
❑K
❑K
< 0.01 acre or assessment area is clear-cut
12. Wetland Intactness — wetland type condition metric (evaluate for Pocosins only)
❑A Pocosin is the full extent (? 90%) of its natural landscape size.
❑B Pocosin type is < 90% of the full extent of its natural landscape size.
13. Connectivity to Other Natural Areas — landscape condition metric
13a. Check appropriate box(es) (a box may be checked in each column). Involves a GIS effort with field adjustment. This metric
evaluates whether the wetland is well connected (Well) and/or loosely connected (Loosely) to the landscape patch, the contiguous
naturally vegetated area and open water (if appropriate). Boundaries are formed by four -lane roads, regularly maintained utility line
corridors the width of a four -lane road or wider, urban landscapes, maintained fields (pasture and agriculture), or open water > 300
feet wide.
Well Loosely
❑A
❑A '
z 500 acres
❑B
❑B
From 100 to < 500 acres
❑C
❑C
From 50 to < 100 acres
❑D
❑D
From 10 to < 50 acres
❑E
❑E
< 10 acres
®F
❑F
Wetland type has a poor or no connection to other natural habitats
13b. Evaluate for marshes only.
[]Yes ❑No Wetland type has a surface hydrology connection to open waters/stream or tidal wetlands.
14. Edge Effect — wetland type condition metric (skip for all marshes'and Estuarine Woody Wetland)
May involve a GIS effort with field adjustment. Estimate distance from wetland type boundary to artificial edges. Artificial edges include
non -forested areas z 40 feet wide such as fields, development, roads, regularly maintained utility line corridors, and clear -cuts. Consider
the eight main points of the compass. Artificial edge occurs within 150 feet in how many directions? If the assessment area is clear cut,
select option "C."
❑A 0
❑B 1 to 4
®C 5to8
15. Vegetative Composition — assessment area condition metric (skip for all marshes and Pine Flat)
❑A Vegetation is close to reference condition in species present and their proportions. Lower strata composed of appropriate
species, with exotic plants absent or sparse within the assessment area.
®B Vegetation is different from reference condition in species diversity. or proportions, but still largely composed of native species
characteristic of the wetland type. This may include communities of weedy native species that develop after clearcutting or clearing.
It also includes communities with exotics present, but not dominant, over a large portion of the expected strata.
❑C Vegetation severely altered from reference in composition, or expected species are unnaturally absent (planted stands of non -
characteristic species or at least one stratum inappropriately composed of a single species), or exotic species are dominant in at
least one stratum.
16. Vegetative Diversity — assessment area condition metric (evaluate for Non -tidal Freshwater Marsh only)
OA Vegetation diversity is high and is composed primarily of native species (< 10% cover of exotics).
❑B Vegetation diversity is low or has > 10% to 50% cover of exotics.
❑C Vegetation is dominated by exotic species (> 50 % cover of exotics).

17. Vegetative Structure — assessment arealwetland type condition metric
17a. Is vegetation present?
®Yes ❑No If Yes, continue to 17b. If No, skip to Metric 18.
17b. Evaluate percent coverage of assessment area vegetation for all marshes only. Skip to 17c for non -marsh wetlands.
®A z 25% coverage of vegetation
❑B < 25% coverage of vegetation
17c. Check a box in each column for each stratum. Evaluate this portion of the metric for non -marsh wetlands. Consider
structure in airspace above the assessment area (AA) and the wetland type (WT) separately.
AA WT
T
o'❑A ❑A Canopy closed, or ready closed, with natural gaps associated with natural processes
m ®B ®B Canopy present, but opened more than natural gaps
O ❑C ❑C Canopy sparse or absent
Z
8 ❑A
❑A
Dense mid-story/sapling layer
r? ®B
®B
Moderate density mid-story/sapling layer
❑C
❑C
Mid-story/sapling layer sparse or absent
❑A
❑A
Dense shrub layer
Z ®B
®B
Moderate density shrub layer
co, ❑C
❑C
Shrub layer sparse or absent
.E ®A
®A
Dense herb layer
_ ❑B
❑B
Moderate density herb layer
❑C
❑C
Herb layer sparse or absent
18. Snags —wetland type condition metric (skip for all marshes)
❑A Large snags (more than one) are visible (> 12 inches DBH, or large relative to species present and landscape stability).
®B Not
19. Diameter Class Distribution —wetland type condition metric (skip for all marshes)
❑A Majority of canopy trees have stems > 6 inches in diameter at breast height (DBH); many large trees (> 12 inches DBH) are
present.
❑B Majority of canopy trees have stems between 6 and 12 inches DBH, few are > 12 inch DBH.
®C Majority of canopy trees are < 6 inches DBH or no trees.
20. Large Woody Debris —wetland type condition metric (skip for all marshes)
Include both natural debris and man -placed natural debris.
❑A Large logs (more than one) are visible (> 12 inches in diameter, or large relative to species present and landscape stability).
®B Not
21. Vegetation/Open Water Dispersion — wetland type/open water condition metric (evaluate for Non -Tidal Freshwater Marsh only)
Select the figure that best describes the amount of interspersion between vegetation and open water in the growing season. Patterned
areas indicate vegetated areas, while solid white areas indicate open water.
❑A ❑B ❑C ❑D
l 5
��� ts✓ iw
22. Hydrologic Connectivity — assessment area condition metric (evaluate for riparian wetlands and Salt/Brackish Marsh only)
Examples of activities that may severely alter hydrologic connectivity include intensive ditching, fill, sedimentation, channelization, diversion,
man-made berms, beaver dams, and stream incision. Documentation required if evaluated as B, C, or D.
❑A Overbank and overland flow are not severely altered in the assessment area.
❑B Overbank flow is severely altered in the assessment area.
❑C Overland flow is severely altered in the assessment area.
®D Both overbank and overland flow are severely altered in the assessment area.
Notes

NC WAM Wetland Rating Sheet
Accompanies User Manual Version 5.0
October 30,
Wetland Site Name W1 Date of Assessment 2019
Wetland Type Bottomland Hardwood Forest Assessor Name/Organization CEC
Notes on Field Assessment Form (Y/N) NO
Presence of regulatory considerations (Y/N) YES
Wetland is intensively managed (Y/N) YES
Assessment area is located within 50 feet of a natural tributary or other open water. (Y/N) YES
Assessment area is substantially altered by beaver (Y/N) NO
Assessment area experiences overbank flooding during normal rainfall conditions (Y/N) YES
Assessment area is on a coastal island (Y/N) NO
Sub -function Ratina Summa
Function
Sub -function
Metrics
Rating
Hydrology
Surface Storage and Retention
Condition
LOW
Sub -surface Storage and
Retention
Condition
MEDIUM
Water Quality
Pathogen Change
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence (Y/N)
NO
Particulate Change
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence (Y/N)
NO
Soluble Change
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence (Y/N)
NO
Physical Change
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence (Y/N)
NO
Pollution Change
Condition
NA
Condition/Opportunity
NA
Opportunity Presence (Y/N)
NA
Habitat
Physical Structure
Condition
LOW
Landscape Patch Structure
Condition
LOW
Vegetation Composition
Condition
MEDIUM
Function Rating Summary
Function
Metrics
Rating
Hydrology
Condition
LOW
Water Quality
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence (Y/N)
NO
Habitat
Condition
LOW
Overall Wetland Rating LOW

NC WAM FIELD ASSESSMENT FORM
Accompanies user manual version om
USACE AID # NCDWR#
Applicant/Owner Name
Wetland Type
Level III Ecoregion
River Basin
County
WCU: Attn Joe Walker
Bottomland Hardwood Forest
Blue Ridge Mountains
Little Tennessee
Jackson
Wetland Site Name
Assessor Name/Organization
Nearest Named Water Body
USGS 8-Digit Catalogue Unit
NCDWR Region
CEC
_ 06010203
Asheville
Evidence of stressors affecting the assessment area (may not be within the assessment area)
Please circle and/or make note on the last page if evidence of stressors is apparent. Consider departure from reference, if appropriate, in
recent past (for instance, within 10 years). Noteworthy stressors include, but are not limited to the following.
• Hydrological modifications (examples: ditches, dams, beaver dams, dikes, berms, ponds, etc.)
• Surface and sub -surface discharges into the wetland (examples: discharges containing obvious pollutants, presence of nearby septic
tanks, underground storage tanks (USTs); hog lagoons, etc.)
• Signs of vegetation stress (examples: vegetation mortality, insect damage, disease, storm damage, salt intrusion, etc.)
• Habitat/plant community alteration (examples: mowing, -.clear -cutting, exotics, etc.)
Is the assessment area intensively managed? ® Yes ❑ No
Regulatory Considerations - Were regulatory considerations evaluated? ®Yes ❑No If Yes, check all that apply to the assessment area.
❑ Anadromous fish
® Federally protected species or State endangered or threatened species
❑ NCDWR riparian buffer rule in effect
❑ Abuts a Primary Nursery Area (PNA)
❑ Publicly owned property
❑ N.C. Division of Coastal Management Area of Environmental Concern (AEC) (including buffer)
® Abuts a stream with a NCDWQ classification of SA or supplemental classifications of HQW, ORW, or Trout
❑ Designated NCNHP reference community
❑ Abuts a 303(d)-listed stream or a tributary to a 303(d)-listed stream
What type of natural stream is associated with the wetland, if any? (check all that apply)
❑ Blackwater
® Brownwater
❑ Tidal (if tidal, check one of the following boxes) ❑ Lunar ❑ Wind ❑ Both
Is the assessment area on a coastal island? ❑ Yes ® No
Is the assessment area's surface water storage capacity or duration substantially altered by beaver? ❑ Yes ® No
Does the assessment area experience overbank flooding during normal rainfall conditions? ® Yes ❑ No
1. Ground Surface Condition/Vegetation Condition — assessment area condition metric
Check a box in each column. Consider alteration to the ground surface (GS) in the assessment area and vegetation structure (VS) in the
assessment area. Compare to reference wetland if applicable (see User Manual). If a reference is not applicable, then rate the assessment
area based on evidence an effect.
GS VS
®A ❑A Not severely altered
❑B ®B Severely altered over a majority of the assessment area (ground surface alteration examples: vehicle tracks, excessive
sedimentation, fire -plow lanes, skidder tracks, bedding, fill, soil compaction, obvious pollutants) (vegetation structure
alteration examples: mechanical disturbance, herbicides, salt intrusion [where appropriate], exotic species, grazing, less
diversity [if appropriate], hydrologic alteration)
2. Surface and Sub -Surface Storage Capacity and Duration —assessment area condition metric
Check a box in each column. Consider surface storage capacity and duration (Surf) and sub -surface storage capacity and duration (Sub).
Consider both increase and decrease in hydrology. A ditch 5 1 foot deep is considered to affect surface water only, while a ditch > 1 foot
deep is expected to affect both surface and sub -surface water. Consider tidal flooding regime, if applicable.
Surf Sub
❑A ❑A Water storage capacity and duration are not altered.
®B ®B Water storage capacity or duration are altered, but not substantially (typically, not sufficient to change vegetation).
❑C ❑C Water storage capacity or duration are substantially altered (typically, alteration sufficient to result in vegetation change)
(examples: draining, flooding, soil compaction, filling, excessive sedimentation, underground utility lines).
3. Water Storage/Surface Relief —assessment area/wetland type condition metric (skip for all marshes)
Check a box in each column. Select the appropriate storage for the assessment area (AA) and the wetland type (Wf).
AA WT
3a. ❑A ❑A Majority of wetland with depressions able to pond water > 1 deep
❑B ❑B Majority of wetland with depressions able to pond water 6 inches to 1 foot deep
❑C ❑C Majority of wetland with depressions able to pond water 3 to 6 inches deep .
®D ®D Depressions able to pond water < 3 inches deep
3b. ❑A Evidence that maximum depth of inundation is greater than 2 feet
❑B Evidence that maximum depth of inundation is between 1 and 2 feet
®C Evidence that maximum depth of inundation is less than 1 foot
J

4. Soil Texture/Structure — assessment area condition metric (skip for all marshes)
Check a box from each of the three soil property groups below. Dig soil profile in the dominant assessment area landscape feature.
Make soil observations within the top 12 inches. Use most recent National Technical Committee for Hydric Soils guidance for regional
indicators.
4a. ❑A Sandy soil
®B Loamy or clayey soils exhibiting redoximorphic features (concentrations, depletions, or rhizospheres)
❑C Loamy or clayey soils not exhibiting redoximorphic features
❑D Loamy or clayey gleyed soil
❑E Histosol or histic epipedon
4b. ®A Soil ribbon < 1 inch
❑B Soil ribbon z 1 inch
4c. ❑A No peat or muck presence
®B A peat or muck presence
5. Discharge into Wetland — opportunity metric
Check a box in each column. Consider surface pollutants or discharges (Surf) and sub -surface pollutants or discharges (Sub). Examples
of sub -surface discharges include presence of nearby septic tank, underground storage tank (UST), etc.
Surf Sub
®A ®A Little or no evidence of pollutants or discharges entering the assessment area
❑B ❑B Noticeable evidence of pollutants or discharges entering the wetland and stressing, but not overwhelming the
treatment capacity of the assessment area
❑C ❑C Noticeable evidence of pollutants or discharges (pathogen, particulate, or soluble) entering the assessment area and
potentially overwhelming the treatment capacity of the wetland (water discoloration, dead vegetation, excessive
sedimentation, odor)
6. Land Use — opportunity metric (skip for non -riparian wetlands)
Check all that apply (at least one box in each column). Evaluation involves a GIS effort with field adjustment. Consider sources draining
to assessment area within entire upstream watershed (WS), within 5 miles and within the watershed draining to the assessment area (5M),
and within 2 miles and within the watershed draining to the assessment area (2M).
WS
5M
2M
❑A
❑A
®A
> 10% impervious surfaces
❑B
❑B
❑B
Confined animal operations (or other local, concentrated source of pollutants
❑C
❑C
❑C
z 20% coverage of pasture
❑D
❑D
❑D
z 20% coverage of agricultural land (regularly plowed land)
®E
®E
®E
z 20% coverage of maintained grass/herb
OF
OF.
OF
z 20% coverage of clear-cut land
❑G ❑G ❑G Little or no opportunity to improve water quality. Lack of opportunity may result from little or no disturbance in
the watershed or hydrologic alterations that prevent drainage and/or overbank flow from affecting the
assessment area.
7. Wetland Acting as Vegetated Buffer— assessment area/wetland complex condition metric (skip for non -riparian wetlands)
7a. Is assessment area within 50 feet of a tributary or other open water?
❑Yes ®No If Yes, continue to 7b.. If No, skip to Metric 8.
Wetland buffer need only be present on one side of the water body. Make buffer judgment based on the average width of wetland.
Record a note if a portion of the buffer has been removed or disturbed.
7b. How much of the first 50 feet from the bank is wetland? (Wetland buffer need only be present on one side of the .water body. Make
bufferjudgment based on the average width of wetland. Record a note if a portion of the buffer has been removed or disturbed.)
❑A z 50 feet
❑B From 30 to < 50 feet
❑C From 15 to < 30 feet
❑D From 5 to < 15 feet
❑E < 5 feet or buffer bypassed by ditches
7c. Tributary width. If the tributary is anastomosed, combine widths of channels/braids for a total width.
0515-feet wide ❑> 15-feet wide ❑ Other open water (no tributary present)
7d. Do roots of assessment area vegetation extend into the bank of the tributary/open water?
❑Yes [:]No
7e. Is stream or other open water sheltered or exposed?
❑Sheltered — adjacent open water with width < 2500 feet and no regular boat traffic.
❑Exposed — adjacent open water with width >_ 2500 feet or regular boat traffic.
Wetland Width at the Assessment Area — wetland type/wetland complex condition metric (evaluate WT for all marshes and
Estuarine Woody Wetland only; evaluate WC for Bottomland Hardwood Forest, Headwater Forest, and Riverine Swamp Forest
only)
Check a box in each column for riverine wetlands only. Select the average width for the wetland type at the assessment area (WT) and
the wetland complex at the assessment area (WC). See User Manual for WT and WC boundaries.
WT
WC
❑A
❑A
>_ 100 feet
❑B
❑B
From 80 to < 100 feet
❑C
El
From 50 to < 80 feet
®D
®D
From 40 to < 50 feet
❑E
❑E
From 30 to < 40 feet
❑F
❑F
From 15 to < 30 feet
❑G
❑G
From 5 to < 15 feet
❑H
❑H
< 5 feet

9. Inundation Duration —assessment area condition metric (skip for non -riparian wetlands)
Answer for assessment area dominant landform.
❑A Evidence of short -duration inundation.(< 7 consecutive days)
®B Evidence of saturation, without evidence of inundation
❑C Evidence of long -duration inundation or very long -duration inundation (7 to 30 consecutive days or more)
10. Indicators of Deposition —assessment area condition metric (skip for non -riparian wetlands and all marshes)
Consider recent deposition only (no plant growth since deposition).
®A Sediment deposition is not excessive, but at approximately natural levels.
❑B Sediment deposition is excessive, but not overwhelming the wetland.
❑C Sediment deposition is excessive and is overwhelming the wetland.
11. Wetland Size —wetland type/wetland complex condition metric
Check a box in each column. Involves a GIS effort with field adjustment. This metric evaluates three aspects of the wetland area: the
size of the wetland type (WT), the size of the wetland complex (WC), and the size of the forested wetland (FVV) (if applicable, see User
Manual). Seethe User Manual for boundaries of these evaluation areas. If assessment area is clear-cut, select "K" for the FW column.
WT
WC
FW (if applicable)
❑A
❑A
❑A '
z 500 acres
❑B
- ❑B
❑B
From 100 to < 500 acres
❑C
❑C
❑C
From 50 to < 100 acres
❑D
❑D
❑D
From 25 to < 50 acres
❑E
❑E
❑E
From 10 to < 25 acres
❑F
❑F
❑F
From 5 to < 10 acres
❑G
❑G
❑G
From 1 to < 5 acres
❑H
❑H
❑H
From 0.5 to < 1 acre
01
®1
01
From 0.1 to < 0.5 acre
❑J
❑J
❑J
From 0.01 to < 0.1 acre
❑K
❑K
❑K
< 0.01 acre or assessment area is clear-cut
12. Wetland Intactness — wetland type condition metric (evaluate for Pocosins only)
❑A Pocosin is the full extent (>_ 90%) of its natural landscape size.
❑B Pocosin type is < 90% of the full extent of its natural landscape size.
13. Connectivity to Other Natural Areas — landscape condition metric
13a. Check appropriate box(es) (a box may be checked in each column). Involves a GIS effort with field adjustment. This metric
evaluates whether the wetland is well connected (Well) and/or loosely connected (Loosely) to the landscape patch, the contiguous
naturally vegetated area and open water (if appropriate). Boundaries are formed by four -lane roads, regularly maintained utility line
corridors the width of a four -lane road or wider, urban landscapes, maintained fields (pasture and agriculture), or open water > 300
feet wide.
Well Loosely
❑A
❑A
Z 500 acres
❑B
❑B ,
From 100 to < 500 acres
❑C
❑C
'From 50 to < 100 acres
❑D
❑D
From 10 to < 50 acres
❑E
❑E
< 10 acres
®F
®F
Wetland type has a poor or no connection to.other natural habitats
13b. Evaluate for marshes only.
❑Yes ❑No Wetland type has a surface hydrology connection to open waters/stream or tidal wetlands.
14. Edge Effect — wetland type condition metric (skip for all marshes and Estuarine Woody Wetland)
May involve a GIS effort with field adjustment. Estimate distance from wetland type boundary to artificial edges. Artificial edges include
non -forested areas Z 40 feet wide such as fields, development, roads, regularly maintained utility line corridors, and clear -cuts. Consider
the eight main points of the compass. Artificial edge occurs within 150 feet in how many directions? If the assessment area is clear cut,
select option "C."
❑A 0
❑B 1 to 4
®C 5to8
15. Vegetative Composition —assessment area condition metric (skip for all marshes and Pine Flat)
❑A Vegetation is close to reference condition in species present and their proportions. Lower strata composed of appropriate
species, with exotic plants absent or sparse within the assessment area.
❑B Vegetation is different from reference condition in species diversity or proportions, but still largely composed of native species
characteristic of the wetland type. This may include communities of weedy native species that develop after clearcutting or clearing.
It also includes communities with exotics present, but not dominant, over a large portion of the expected strata.
®C Vegetation severely altered from reference in composition, or expected species are unnaturally absent (planted stands of non -
characteristic species or at least one stratum inappropriately composed of a single species), or exotic species are dominant in at
least one stratum.
16. Vegetative Diversity — assessment area condition metric (evaluate for Non -tidal Freshwater Marsh only)
❑A Vegetation diversity is high and is composed primarily of native species (< 10% cover of exotics).
®B Vegetation diversity is low or has > 10% to 50% cover of exotics.
❑C Vegetation is dominated by exotic species (> 50 % cover of exotics).

17. Vegetative Structure —assessment area/wetland type condition metric
17a. Is vegetation present?
®Yes []No If Yes, continue to 171b. If No, skip to Metric 18.
17b. Evaluate percent coverage of assessment area vegetation for all marshes only. Skip to 17c for non -marsh wetlands.
®A t 25% coverage of vegetation
❑B < 25% coverage of vegetation
17c. Check a box in each column for each stratum. Evaluate this portion of the metric for non -marsh wetlands. Consider
structure in airspace above the assessment area (AA) and the wetland type (WT) separately.
AA Vyi
cCIA[]A Canopy closed, or nearly closed, with natural gaps associated with natural processes
W ❑B ❑B Canopy present, but opened more than natural gaps
O ®C ®C Canopy sparse or absent
r
S ❑A
❑A
Dense mid-story/sapling layer
v ❑B
®C
❑B
®C
Moderate density mid-story/sapling layer
Mid-story/sapling layer
sparse or absent
2 []A[]A
Dense shrub layer
m ❑B
❑B
Moderate density shrub layer
N ®C
®C
Shrub layer sparse or absent
.2 ®A
®A
Dense herb layer
To ❑B
❑B
Moderate density herb layer
❑C
❑C
Herb layer sparse or absent
18. Snags — wetland type condition metric (skip for all marshes)
❑A Large snags (more than one) are visible (> 12 inches DBH, or large relative to species present and landscape stability).
®B Not A
19. Diameter Class Distribution — wetland type condition metric (skip for all marshes)
❑A Majority of canopy trees have stems > 6 inches in diameter at breast height (DBH); many large trees (> 12 inches DBH) are
present.
❑B Majority of canopy trees have stems between 6 and 12 inches DBH, few are > 12 inch DBH.
®C Majority of canopy trees are < 6 inches DBH or no trees.
20. Large Woody Debris — wetland type condition metric (skip for all marshes)
Include both natural debris and man -placed natural debris.
❑A Large logs (more than one) are visible (> 12 inches in diameter, or large relative to species present and landscape stability).
®B Not
21. Vegetation/Open Water Dispersion — wetland type/open water condition metric (evaluate for Non -Tidal Freshwater Marsh only)
Select the figure that best describes the amount of interspersion between vegetation and open water in the growing season. Pattemed
areas indicate vegetated areas, while solid white areas indicate open water.
❑A ❑B ❑C ❑D
22. Hydrologic Connectivity — assessment area condition metric (evaluate for riparian wetlands and Salt/Brackish Marsh only)
Examples of activities that may severely alter hydrologic connectivity include intensive ditching, fill, sedimentation, channelization, diversion,
man-made berms, beaver dams, and stream incision. Documentation required if evaluated as B. C, or D.
❑A Overbank and overland flow are not severely altered in the assessment area.
❑B Overbank flow is severely altered in the assessment area.
❑C Overland flow is severely altered in the assessment area.
®D Both overbank and overland flow are severely altered in the assessment area.
Notes

NC WAM Wetland Rating Sheet
Accompanies User Manual Version 5.0
Wetland Site Name W2 Date of Assessment
Wetland Type Bottomland Hardwood Forest Assessor Name/Organization
Notes on Field Assessment Form (Y/N)
Presence of regulatory considerations (Y/N)
Wetland is intensively managed (Y/N) .
Assessment area is located within 50 feet of a natural tributary or other open water (Y/N)
Assessment area is substantially altered by beaver (Y/N)
Assessment area experiences overbank flooding during normal rainfall conditions (Y/N)
Assessment area is on a coastal island (Y/N)
Sub -function Ratina Summa
October 30,
2019
CEC
NO
vGe
YES
NO
NO
vGc
NO
Function
Sub -function
Metrics
Rating
Hydrology
Surface Storage and Retention
Condition
LOW
Sub -surface Storage and
Retention
Condition
MEDIUM
Water Quality
Pathogen Change
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence (Y/N)
NO
Particulate Change
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence (Y/N)
NO
Soluble Change
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence (Y/N)
NO
Physical Change
Condition
LOW
Condition/Opportunity
'LOW -
Opportunity Presence (Y/N)
NO
Pollution Change
Condition
NA
Condition/Opportunity
NA
Opportunity Presence (Y/N)
NA
Habitat
Physical Structure
Condition
LOW
Landscape Patch Structure
Condition
LOW
Vegetation Composition
Condition
LOW
Function Ratina Summa
Function
Metrics
Rating
Hydrology
Condition
LOW
Water Quality
Condition
LOW
Condition/Opportunity
LOW
Opportunity Presence (Y/N)
NO
Habitat
Condition
LOW
Overall Wetland Rating LOW

Attachment D
DMS Acceptance Letter

ROY COOPER
Gosanor
MICHAEL S REGAN
S—dwr
TIM BAUMGARTNER
D6erme
Joe Walker
Western Carolina University
3476 Old Cullowhee Road
Cullowhee, NC 28723
0
NORTH CAROLINA
Finfroronne tal Qualay
November 13, 2019
Project: WCU Master Plan Improvements IP Modification
Expiration of Acceptance: 5/13/2020
County: Jackson
This Is a conditional acceptance letter.
The purpose of this letter is to notify you that the NCDEQ Division of Mitigation Services (DMS) is willing to
accept payment for compensatory mitigation for impacts associated with the above referenced project as
indicated in the table below. Please note that this decision does not assure that participation in the DMS in -
lieu fee mitigation program will be approved by the permit issuing agencies as mitigation for project impacts.
It is the responsibility of the applicant to contact permitting agencies to determine if payment to the DMS will
be approved. You must also comply with all other state, federal or local government permits, regulations or
authorizations associated with the proposed activity including G.S. § 143-214.11.
This acceptance is valid for six months from the date of this letter and is not transferable. If we have not
received a copy of the Issued 404 Permit/401 Certification within this time frame, this acceptance will
expire. It is the applicant's responsibility to send copies of the permits to DMS. Once DMS receives a copy
of the permit(s) an invoice will be issued based on the required mitigation in that permit and payment must
be made prior to conducting the authorized work. The amount of the in -lieu fee to be paid by an applicant is
calculated based upon the Fee Schedule and policies listed on the DMS website.
Based on the information supplied by you in your request to use the DMS, the impacts for which you are
requesting compensatory mitigation credit are summarized in the following table. The amount of mitigation
required and assigned to DMS for this impact is determined by permitting agencies and may exceed the
impact amounts shown below.
0203" Riparian Wetland 1 0.35
*DMS proposes to provide the mtigation In the Liftle Tennessee River Basin. Upon receipt of payment,
DMS will take responsibility for providing the compensatory mitigation. The mitigation will be performed in
accordance with the In -Lieu Fee Program instrument dated July 28, 2010 and 15A NCAC 02B .0295 as
applicable. Thank you for your interest in the DMS in -lieu fee mitigation program. If you have any questions
or need additional information, please contact Kelly Williams at [phone].
cc: Alea Tuttle, agent
Sincerely,
Jam s. B Stanfill
Asset Management Supervisor
North Carotlre Depanmaa ofUwha ibl p.Wiq I DWtsim of Wilgaam Smkea
2O wJo Sheet 11652 Mall service Ce I bkigh North Caru&a 27699-1652
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