20180582 Ver 2_Hearing Officers Report_20200406

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April 6, 2020
MEMORANDUM
To: Danny Smith
Director, Division of Water Resources
From: Lon Snider, Supervisor, Winston-Salem Regional Office DocuSigned by:
Division of Water Resources, Water Sciences Section ' T. Sti�dcr
EL145B49E225C94EA...
Subject: Hearing Officer's Report and Recommendations
Cashiers Canoe Club Development, LLC
Individual 401 Water Quality Certification — DWR Project #20180582 Ver 2
Jackson County
I served as the Hearing Officer for the subject Public Hearing held at the Albert Carlton -Cashiers
Community Library in Cashiers, NC on September 5, 2019. The public hearing was held under the
authority of Title 15A NCAC 02H .0503. The purpose of this public hearing was to receive
comment on the Division of Water Resources' 401 Water Quality Certification (401 WQC)
application submitted by Cashiers Canoe Club Development, LLC (Canoe Club). A 401 Water
Quality Certification is needed to conduct activities within Cashiers Lake in Jackson County.
In addition to listening to oral comments at the public hearing, I have reviewed all written
comments received prior, during, and after the public comment period. In preparation of this
report, I have considered all of the public comments, the public record, discussions with Division
of Water Resources (DWR) staff related to the rules, and their review of the application for the
project.
The report has been prepared using the following outline:
1. Site History / Background
11. Public Hearing Summary
Ill. Comments and Responses
IV. Recommendations
V. Summary
V1. Appendices
I. History / Background
On April 12, 2019, the Canoe Club submitted an application fora 401 Water Quality Certificate
(Appendix A). The Canoe Club had previously applied to DWR on April 26, 2018. DWR
requested additional information on June 6, 2018 and January 10, 2019. On April 12, 2019
the applicant requested to withdraw their application and to reapply in order to address
comments received from the Division during the review period.
The Canoe Club is proposing dredging and development activities within Cashiers Lake for the
purposes of improving lake function and development activities.
The Canoe Club is proposing to permanently fill 0.57 acres of wetland for construction of a
forebay and equipment access to the forebay, to permanently impact 0.34 acres of wetlands

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and 1.39 acres of open water for bulkhead construction and shoreline stabilization activities,
to permanently dredge 6.22 acres of wetlands to reclaim open water accessibility, and to
temporarily disturb 3.34 acres of open water for temporary construction access and erosion
control measures.
The Canoe Club has revised the application throughout the review period and has
subsequently reduced the impacts originally proposed (130 linear feet of streams for
subdivision development, 17.37 acres of open water dredging)
Under the authority of Title 15A NCAC 02H .0503, DWR held a public comment period from
July 29, 2019 until October 7, 2019 to accept public input on the application. The public
comment period included the public hearing described below.
In accordance with Title 15A NCAC 02H .0503, notice of the public hearings and availability of
the 401 WQC application was posted on DWR's website and was emailed to the DWR 401
mailing list. (Appendix B). The public comment period ended on October 7, 2019.
II. Public Hearing
A public hearing was held September 5, 2019, at 6 p.m. at the Albert Carlton -Cashiers
Community Library in Cashiers, NC. The public hearing was held under the authority of Title
15A NCAC 02H .0503. This was a public hearing to receive public comment for the DWR 401
WQC application (Appendix A) submitted by the Canoe Club in order to conduct lake and
development improvement activities in Cashiers Lake in Cashiers NC in Jackson County.
Seventy-three people attended the public hearing, including five staff members from the
Department. A total of sixty-eight individuals signed the attendance sign -in sheets at the
registration table (Appendix C). The hearing officer provided opening remarks and Sue
Homewood from DWR presented background information on the 401 WQC process and the
proposed application before the hearing was opened for public comment. Twenty-four
individuals registered in advance of the hearing to provide comments, and two additional
individuals asked to speak when the hearing officer asked the audience if there were any
others who wished to speak. Two individuals who registered to speak donated their time to
another speaker and one individual who registered to speak declined to do so when called
upon, for a total of twenty-three speakers. Speakers were given three minutes for initial
presentations. The list of speakers is included (Appendix C). Staff notes pertaining to all
verbal comments are included as well as an audio file of the hearing. (Appendices D and Q.
DWR also received 26 written comments during the public comment period from local and
state government agencies, individual citizens, and citizen groups (Appendix F). Some of the
comments were written transcripts of the comments provided during the public hearings. 38
comments (written & verbal) were opposed to the project and 11 were in favor. A summary
of the verbal comments received during the hearing and the written comments received
during the comment period, along with detailed responses that have a direct impact on the
certification decision making process are included in Sections III and IV below.
III. Comments Received with Responses
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The following is a summary of the comments received during the September 5, 2019 public
hearing and emails and other written comments received by DWR during the public comment
period.
• Comments were received expressing concerns about property rights, deed rights, lake
rights, and access (road) rights.
These comments are outside of the evaluation criteria established in N.C.
Administrative Codes for the 401 WQC review and should be directed to real estate or
property law attorneys. All 401 Certifications issued by the Division state:
"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."
• Comments were received expressing concerns that there may be damage to their
residential properties/structures from truck traffic as a result of dredge material
transportation/disposal.
These comments are outside of the evaluation criteria established in N.C.
Administrative Codes for the 401 WQC review and should be directed to property
law/personal attorneys.
• Comments were received expressing concerns for pollutants that may be present within
the dredge material. Comments received expressed concerns for mobilization of
pollutants to downstream waters during dredging and/or reuse within Cashiers Lake and
expressed concern for property and/or groundwater contamination from upland
disposal of dredge material. One commenter noted a prior history of plastics company
upstream of Cashiers Lake. One commenter noted the high levels of Chromium that was
reported in the application materials.
The applicant submitted a Pre -Dredging Assessment Plan on November 27, 2019 and
upon review by staff submitted a revised plan on December 20, 2019. The Division
approved the plan on January 22, 2020. The applicant submitted a Pre -Dredging
Assessment report on March 5, 2020. The report indicated that two constituents were
identified above laboratory reporting results. Sampling results indicated that 1-
Methy1napthalene and 2-Methylnapthalene were present at sampling location 5-12
only, and Acetone was present at sampling locations S-6 and S-8. Acetone is a
common laboratory contaminant and therefore was not considered to be present in
site sediment. The concentration of 1-Methylnapthalene was present above the
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Protection of Groundwater (PSRG) standard of 0.11 mg/kg but below the Residential
PSRG of 18 mg/kg. Additional sampling was conducted to provide for further
evaluation of the Synthetic Precipitation Leaching Procedure by EPA method 1312. A
report addendum was received by the Division on March 26, 2020 which indicates that
the results of the SPLP analysis indicate that the concentration of 1-Methylnapthalene
was below the Interim Allowable Concentration (IMAQ. Staff within the Division of
Solid Waste have confirmed that the material meets the qualifications for beneficial
fill and may be used as such.
• Comments were received expressing support for dredging of the upper portion of
Cashiers Lake because it will likely solve/improve ongoing problems of flooding on Frank
Allen Road and the properties above the lake, provide aesthetic improvements and
benefit tourism.
No response necessary.
• Comments were received requested that sediment deposition be addressed in a
permanent manner for the future protection of roads and properties above the lake.
Cashiers Canoe Club has proposed a forebay located at the inlet of the lake to capture
sediment as it enters the lake. Cashiers Canoe Club proposes to regularly maintain the
forebay to prevent future sedimentation within the lake.
• Comments were received that expressed concern for additional traffic from proposed
new development, that it does not provide affordable housing that is needed in Cashiers,
and that new development would strain existing local facilities (fire, school, medical
facilities).
These comments are outside of the evaluation criteria established in N.C.
Administrative Codes for the 401 WQC review and should be directed to local public
officials.
• Comments were received that expressed the concern regarding cumulative impacts
from the project.
The applicant has indicated that there will be no additional impacts to jurisdictional
waters from the project. See additional comments and responses within this
document regarding downstream water quality impacts from the project.
• Comments were received that expressed the opinion that Chattooga River water quality
is already degraded and not attaining its designated uses and that DWR must deny
requests for 401 WQCs for every real estate project which threatens even de minimis
adverse discharges.
The comments received specifically indicated that the Chattooga River has been
degraded by prior development within the watershed and therefore no new
development should be allowed. These comments are outside of the evaluation
criteria established in N.C. Administrative Codes for the 401 WQC review. The Division
is without authority to categorically deny all 401 WQC applications within a
geographic area. Pursuant to 15A NCAC 02H .0506 the project has been reviewed to
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determine that existing uses are not removed or degraded by the proposed discharge
(emphasis added) to classified surface waters.
• Comments were received expressing concerns about invasive plant species (specifically
Parrot Feather and Yellow Flag Iris) within the existing wetlands and how migration of
the invasive species will be controlled during dredging activities. The comments
expressed the opinion that invasive removal from dredging would be a positive outcome
of the project. A comment was also received that noted that dredging could also help
with mosquito control.
On October 28, 2019 the Division issued a request to the applicant to provide an
invasive species management plan in response to these concerns. On November 27,
2019 the applicant responded to the Division with a detailed response indicating that
"the use of floating turbidity curtains will serve as an effective barrier against the
transport of any potentially dislodged plant material and thereby reducing the
potential of downstream transport of invasive aquatic plants."
• Comments were received that the current wetland provides a natural method of
pollutant removal and protects downstream waters which should be retained or
replaced.
The applicant proposes to retain approximately 5 acres of wetlands within Cashiers
Lake. In addition, a forebay will be constructed at the top of the lake which will provide
sediment filtration and pollutant removal. Finally, the lake itself will provide further
sediment and pollutant removal prior to discharge into the Chattooga River.
• Comments were received that question whether the proposed activities will interfere
with the downstream owners' reasonable use and rights.
These comments are outside of the evaluation criteria established in N.C.
Administrative Codes for the 401 WQC review and should be directed to private
attorneys. All 401 Certifications issued by the Division state:
"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."
• Comments were received that question whether the removal of shading vegetation will
increase downstream water temperatures.
The outlet of Cashiers Lake includes a "bottom release" structure ensuring that
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downstream water temperatures are not influenced by surface water temperatures
within the lake.
• Comments were received that question whether the dredging activities will affect the
aquifers near or around the lake.
The applicant is not proposing to permanently modify the ordinary water level within
the lake therefore no changes to the water table are to be expected.
• Comments were received that DWR should consider this application review as an
opportunity for mitigation to solve long-term stormwater problems within the
watershed and that the agency should consider funding long term stormwater programs
or creating a trust to do so.
This request is outside of the mitigation criteria established for stream and wetland
impacts in N.C. Administrative Codes for the 401 WQC review and would require
development of a local stormwater program which would be outside of the purview
of this 401 WQC application review.
• Comments were received expressing concerns for the protection of downstream ORW
waters and National Wild and Scenic River, as well as fisheries habitat, from increased
sedimentation during dredging activities and from dredging waste areas adjacent to the
river.
Specific management strategies have been developed to protect Outstanding
Resource Waters in North Carolina. In accordance with the State Pollution Control Act
of 1973 and 15A NCAC 04 (delegated to Jackson County for implementation), the
project will be subject to stringent design standards for erosion control measures in
sensitive watersheds.
• Comments were received that expressed concerns that the lake level is proposed to be
reduced by four feet during dredging activities and that the lake would only have the
ability to store the volume of water from a three-inch rain event in the watershed within
the 4 feet of drawdown. Precipitation events of greater than three inches are common
in Jackson County and there was concern for downstream turbidity and dissolved oxygen
levels as a result of dredging activities. A commenter suggested that a complete pump
around should be required to protect downstream waters.
The Division has confirmed with Jackson County Erosion Control Permitting staff that
this concern will be specifically reviewed in accordance with their delegated authority
under the State Pollution Control Act of 1973 and 15A NCAC 04, and that the project
will be subject to stringent design standards for erosion control measures in sensitive
watersheds.
• Comments were received that expressed concern that the applicant has proposed
mitigation for the impacts in an adjacent watershed.
In accordance with 15A NCAC 02H .0506(1) "Mitigation required by the U.S. Army
Corps of Engineers shall be considered to constitute the mitigation required by this
Certification unless the Director determines that the mitigation proposal does not
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meet the criteria established in Subparagraph (6) of this Paragraph. The mitigation
provided meets Subparagraph (6) and therefore the proposed mitigation plan meets
the evaluation criteria established in 15A NCACO2H.0506(1) and comments regarding
the appropriateness of the mitigation plan should be directed to the U.S. Army Corps
of Engineers.
• Comments were received that expressed concerns for increased wastewater from the
future development adjacent to Cashier Lake into a Wastewater Treatment Plant
(WWTP) with history of NPDES violations. The commenter specifically stated that flow
that was previously allocated to the WWTP but not yet realized from this project would
be considered an expansion of a discharge and would be in violation of 15A NCAC 02B
.0225.
Cashiers Canoe Club has provided documentation that the WWTP has allocated
capacity for the proposed future development. Since the WWTP was upgraded in May
2008 there have been six limit violations (2 for TSS, 4 for BOD), there have been no
limit violations in 2018. Flow increases under the current allocated flow should not
inhibit the plants ability to properly treat the flow. The commenter's interpretation of
15A NCAC 02B .0225 is incorrect, an expansion of a WWTP would be an expansion of
existing permitted flow, not an addition of flow that is within the capacity of the
existing facility.
• Comments were received expressing concerns about future development that was
proposed as part of the overall Cashiers Canoe Club Development. Comments included
general concerns for degradation of downstream waters due to increased development
in the watershed, increased downstream turbidity and sedimentation as a result of
future development activities, as well as specific concerns that the applicant was relying
on outdated stormwater permits and/or had provided insufficient/incomplete
information regarding the current stormwater management plan. Some comments
included the opinion that the watershed has already been substantially degraded due to
development within the watershed and that no new development should be allowed at
all.
DWR does not have the authority to prevent development within the watershed. Any
development associated with this project, or other projects within the watershed, will
be subject to 15A NCAC -2H .1021 which is a specific development stormwater
management strategy developed to protect Outstanding Resource Waters in North
Carolina. The applicant has acknowledged the future requirement to secure
appropriate stormwater permits under these rules prior to any future development
within the Cashiers Canoe Club Development.
IV. Certification Recommendations
Based on the review of public comments, the application, the North Carolina General Statutes
and Administrative Code, discussions with DWR staff, and additional information provided by
the applicant, I offer the following comments and recommendations on the criteria for
issuance of a 401 WQC pursuant to 15A NCAC 02H .0506(b).
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15A NCAC 02H .0506(b)
(1) Has no practical alternative under the criteria outlined in Paragraph (f) of this Rule.
Paragraph (f) states: "A lack of practical alternatives may be shown by demonstrating
that, considering the potential for a reduction in size, configuration or density of the
proposed activity and all alternative designs the basic project purpose cannot be
practically accomplished in a manner which would avoid or result in less adverse
impact to surface waters or wetlands."
The project purpose is to dredge and conduct development improvement activities to Cashiers
Lake in Cashiers, North Carolina. Given that the purpose of the project is to improve access
and aesthetics of the existing lake by dredging, the only alternative to consider would be not
to conduct the activity. The Canoe Club has continued to refine the avoidance and
minimization practices in response to additional information requests from DWR. A more
detailed discussion of avoidance and minimization can be found below.
Recommendation: None. The applicant has sufficiently demonstrated that there is no
practical alternative that can accomplish the project-s basic purpose with less adverse impact
to surface waters or wetlands.
(2) Will minimize adverse impacts to the surface waters based on consideration of
existing topography, vegetation, fish and wildlife resources, and hydrological
conditions under the criteria outlined in Paragraph (g) of this Rule.
Paragraph (g) states: "Minimization of impacts may be demonstrated by showing that
the surface waters or wetlands are able to continue to support the existing uses after
project completion, or that the impacts are required due to:
(1) The spatial and dimensional requirements of the project; or
(2) The location of any existing structural or natural features that may dictate the
placement or configuration of the proposed project; or
(3) The purpose of the project and how the purpose relates to placement,
configuration or density.
The applicant has minimized impacts to surface waters and wetlands through multiple project
revisions. The permanent impacts will be 0.57 acres of wetland for construction of a forebay
and equipment access to the forebay, 0.34 acres of wetlands and 1.39 acres of open water for
bulkhead construction and shoreline stabilization activities, and 6.22 acres of wetlands to
reclaim open water accessibility by dredging actions. The Canoe Club has reduced all impacts
from adjacent development activities by utilizing bridges for future road construction. In
addition, the Canoe Club has removed open water dredging activities from the project
activities.
The applicant has committed to the following actions to ensure downstream water quality
protection:
• Minimum release to downstream waters will be 70% of inflow to lake during project
activities and refilling of the lake upon completion of all activities.
• Inspection of all erosion control measures after each precipitation event and
immediately maintain and/or repair as necessary.
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• Daily monitoring of turbidity in downstream waters. All work will cease immediately
upon observation of any concerns and DWR and NCWRC will be immediately notified.
Recommendation: The applicant has sufficiently demonstrated that impacts to surface
waters and wetlands are required for the purpose of the project. The 401 approval should
include requirements for monitoring of downstream flows and turbidity and should include
immediate cease activity and reporting requirements for any observations of increased
turbidity. The 401 approval should also require compliance with their approved sediment and
erosion control plan at all times.
(3) Does not result in the degradation of groundwaters or surface waters.
The main risk to surface waters from the project activities will be increased turbidity during
dredging and bulkhead construction activities. The applicant has committed to isolating the
flowing stream from these activities, use of a floating turbidity curtains and a daily monitoring
of turbidity in downstream waters. Proper erosion and sedimentation control measures for
sensitive watersheds will be required for the project in accordance with the sedimentation and
erosion control Certificate of Plan Approval issued by Jackson County. The applicant is aware
that all adjacent future development activities will be subject to Stormwater Regulations for
Outstanding Resource Waters and will secure the necessary permits prior to initiation of any
adjacent development activities.
Recommendation: The project is not expected to violate water quality standards if the
conditions in the 401 Water Quality Certification are fully complied with by the applicant (or
its successor). The 401 WQC should be contingent on the issuance of a sedimentation and
erosion control Certificate of Plan Approval issued by Jackson County, and should be
conditioned to require issuance of appropriate state storm water permits prior to initiating any
future adjacent development activities.
The 401 approval should also require a pre -construction meeting with the construction
contractors and DWR staff to review the conditions and requirements of the certification.
(4) Does not result in cumulative impacts, based upon past or reasonably anticipated
future impacts, that cause or will cause a violation of downstream water quality
standards.
Cumulative impacts are those impacts that would result from the incremental effects of the
project added to other past, present and reasonably foreseeable future activities (15A NCAC
01C. 0103). This includes secondary impacts or impacts from future activities that occur as a
result of the proposed project. The proposed project will consist of temporary and permanent
water quality impacts from the dredging and development improvements within Cashiers
Lake. The temporary and permanent impacts will be reduced through avoidance and
minimization efforts and proper erosion and sedimentation control design and
implementation. Any additional development occurring immediately adjacent to Cashiers
Lake will be subject to local, state, and federal regulations that address stream and wetland
impacts, sediment and erosion control management, stormwater management, and
watershed protection.
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Recommendation: The project is not expected to result in cumulative impacts that violate
water quality standards if the conditions in the 401 WQC are fully implemented by the
applicant (or its successor).
(5) Provides for protection of downstream water quality standards through the use of on -
site stormwater control measures.
Stormwater management for future impervious surfaces will be regulated through the state
program for Outstanding Resource Waters as required in 15A NCAC 02H .1021.
Recommendation: Session Law 2017-10 prohibits DWR from requiring on -site stormwater
management through a 401 WQC. The 401 WQCshould be conditioned to require compliance
with all applicable state stormwater permits for future developments.
(6) Provides for replacement of existing uses through mitigation.
Both federal and state requirements allow for the purchase of in lieu fee credits to offset
unavoidable impacts to wetlands. In accordance with 15A NCAC 02H .0506(1) "Mitigation
required by the U.S. Army Corps of Engineers shall be considered to constitute the mitigation
required by this Certification unless the Director determines that the mitigation proposal does
not meet the criteria established in Subparagraph (6) of this Paragraph. The Canoe Club's
proposed mitigation plan meets Subparagraph (6) and therefore the proposed mitigation plan
meets the evaluation criteria established in 15A NCAC 02H .0506(1).
Recommendation: The 401 WQC should be conditioned to include language requiring the
proposed mitigation plan be finalized and secured prior to commencement of in -water
activities.
V. Summary
Public comments received during the public hearing and public comment period focused on
several areas, including the degradation of water quality in the Chattooga River,
sedimentation and erosion control, stormwater impacts from future development,
aesthetics, invasive species, property rights, and concerns for pollutant dispersal through
dredge material disposal. Due to the number of public comments, many of which expressed
concerns on the same issues, each comment is not addressed individually. Only comments
that have direct relevance to the certification decision have been addressed in the
recommendations (Section IV).
As stated above, a thorough review of all public comments received and the project record
has been conducted, and additional insight has been obtained through discussions with DWR
staff and additional information received by the applicant. Based on all of this information, it
is my recommendation that the 401 Water Quality Certification be issued and subject to the
conditions included in the recommendations in Section IV. It is further recommended that
DWR include any additional conditions necessary to ensure that the project will meet state
water quality standards.
VI. Appendices (available on Laserfiche)
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A. April 12, 2019 401 Water Quality Certification Application
a. Laserfiche Folder Name: 20180582 Ver2_401 Reapplication_20190412
b. Laserfiche link:
https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=868293&dbid=0&r
epo=WaterResources
B. Notice of Public Hearings —July 29, 2019
a. Laserfiche Filename: 20180582 Ver 2 Public Notice of Public Hearing 20190729
b. Laserfiche link:
https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=954355&dbid=0&r
epo=WaterResources
C. Public Hearing Sign In sheets (Speakers and Non -Speakers)
a. Laserfiche Filename: 20180582 Ver 2 Public Hearing Sign In Sheets 20190905
b. Laserfiche link:
httpsWedocs.deg.nc.gov/WaterResources/DocView.aspx?id=973168&dbid=0&r
epo=WaterResources
D. Public Hearing Staff Notes
a. Laserfiche Filename: 20180582 Vert Staff Notes 20190905
b. Laserfiche link:
https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=987569&dbid=0&repo=W
aterResources
E. Public Hearing Audio File
a. Laserfiche Filename: 20180582 Ver 2 Public Hearing Audio 20190905
b. Laserfiche link:
https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=965269&dbid=0&repo=W
aterResources
F. Written comments received during the comment period, including at the public
hearings
a. Laserfiche Folder Name: Written Comments Received
b. Laserfiche link:
https://edocs.deg.nc.gov/WaterResources/Browse.aspx?id=973159&dbid=0&repo=Wa
terResources
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