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HomeMy WebLinkAbout20090569 Ver 2_401 Application_20100210I I coEngineering A division of The John R. McAdams Company, Inc. LETTER OF TRANSMITTAL To: Cyndi Karoly Supervisor North Carolina DENR Division of Water Quality 1650 Mail Service Center Raleigh, North Carolina 27699-1650 Re: Chinquapin Irrigation Supply - NWP 18 & GC 3705 I am sending you the following item(s): COPIES DATE NO. DESCRIPTION 5 2/01/10 Response to Comments; PCN 1 2/01/10 79531 Check No. 79531; $240.00 These are transmitted as checked below: ? As requested ® For approval ® For review and comment Remarks: o R - oS Loq U a, Date: February 1, 2010 REGULAR MAIL Job No.: TRL-08000 I DAL ID ti Llj' k Lf L5 ® For your use `'EB 2010 ? For signature BEN- eicOtiiuii Y- ? wETUMS AND STORWIATER SRANCH Copy to: Signed: George Buchholz, REM, PWS Environmental Scientist FOR INTERNAL USE ONLY ? Copy Letter of Transmittal Only to File ® Copy Entire Document to File 2905 Meridian Parkway, Durham, North Carolina 27713 PO Box 14005, RTP, North Carolina 27709 EcoEngineering A division of The John R. McAdams Company, Inc. February 1, 2010 Ms. Lori Beckwith Corps Regulator Official U.S. Army Corps of Engineers Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 Mr. Roger Edwards Regional Office Supervisor NCDENR - DWQ Surface Water Protection Section 2090 US Highway 70 Swannanoa, North Carolina 28778 Research Triangle Park, NC Post Office Box 14005 Research Triangle Park, North Carolina 27709 2905 Meridian Parkway Durham, North Carolina 27713 800-733-5646 919-287-4262 919-361-2269 Fax Ms. Shannon Deaton Manager North Carolina Wildlife Resource Commission Division of Inland Fisheries 1721 Mail Service Center Raleigh, North Carolina 27699 Re: Chinquapin Irrigation Supply - NWP 18 & GC 3705 Response to Comments; Pre-Construction Notification Action ID: SAW 2009-00963 TRL-08000 Dear Sir/Madam: To address the concerns of the U.S. Army Corps of Engineers, NCDENR - DWQ Surface Water Protection Section, and the North Carolina Wildlife Resource Commission, EcoEngineering on behalf of Chinquapin has undertaken the following tasks: Collection of gage data at the withdrawal location for the months of September and October 2009; presentation and analysis of the data is presented in Section 1 of this response Provided a written response to the agency comments which is part of this letter - Provided a revised PCN - Provided additional project history for completeness of the application, and www.ecoengr.com i Design Services Focused On Client Success EcoEngineering A division of The John R. McAdams Company; Inc. February 1, 2010 Response to Comments TRL-08000 Page 2 In addition to the above tasks EcoEngineering recommends the following permit conditions: 1. Withdrawal from Robinson Creek shall not exceed 75,000 gallons per day. The pumping rate shall not exceed 52 gallons per minute. (52 gpm x 60 min. x 24 hrs. = 74,880 gallons per day.) 2. Pumping shall not occur if stream discharge is at or below the stated 7Q10 level of 1.3 CFS which corresponds to a gauge depth of 1.42 feet at the current cross-section location and gage installed during Fall 2009. 3. Daily stream flow records shall be submitted on an annual basis. Daily withdrawal amounts shall also be submitted on an annual basis. This data shall be submitted with the annual submittal for Tulip Pond as required under Division of Water Resources G.S. 143-215.22H. Below please find our response to comments from your respective regulatory agency. Also, please find attached a revised Pre-Construction Notification and supporting documentation. USACE - Comments Dated June 29, 2009 Comment 1: Please explain how the weight of the pump would keep it submerged and how no excavation and/or filling of the stream would be necessary. Is there a pad for the pump? If so, what would this have on the stream (area filled) and what would it be composed of (e.g., concrete, rip rap, etc.)? Response 1: The submersible pump will be powered by a 25 horsepower, 460 volt, and 3 phase motor capable of pumping 100 gallons per minute at 390 feet of resistance. The submersible pump is 2.5 feet wide and 4.5 long and it contains a screened intake opening of 0.25 inches. The submersible pump will be attached to a custom fabricated aluminum submersible sled (approximately 3 feet wide and 5 feet long). The sled will be anchored by two cables stretched up stream and staked in the banks (attached Section 2 - Figure 5 Detail Sheet). The submersible pump and sled assemblage, which weighs approximately 500 pounds, will sink to the bottom of the stream. Due to its weight and anchoring cables, it is EcoEngineering A division of The John R. McAdams Company, Inc. February 1, 2010 Response to Comments TRL-08000 Page 3 anticipated anchoring the assemblage to the stream bed will not be necessary. Comment 2: Please provide a map that shows the exact location of the proposed pump, the exact location of any other fill and/or dredging, and the location of the buffer to be removed. . Response 2: Attached in Section 2 are Figures 1 through 5 which show the location of the proposed submersible pump, location of the buffer to be temporarily removed, access to the stream, and Tulip Pond. No other fill and/or dredging impacts are anticipated for the proposed project. Comment 3: As is required by our Regional Condition 2.7, the North Carolina Wildlife Resources Commission (WRC) reviewed this project and provided a comment letter (attached). According to the letter, Robinson Creek supports wild brook trout. Based on possible adverse effects to the brook trout, the agency could not concur with a permit for this project as proposed. They requested that you provide specific additional information that clearly demonstrates that the proposed withdrawal would not adversely affect trout. Please respond to comments 1-4 of the WRC letter and send this information to this office and the WRC. Response 3: Responses are provided below to NCWRC comments dated .June 12, 2009. Comment 4: Section 5a. in the application is marked "yes" regarding federally protected species or habitat. Please detail your findings. Response 4: The USFWS internet service, accessed May 4, 2009, lists Carolina northern flying squirrel (Glaucomys sabrinus coloratus), Indiana bat (Myotis sodalis), Appalachian elktoe (Alasmidonta raveneliana), small whorled pogonia (Isotria medeoloides), swamp pink (Helonias bullata), and rock gnome lichen (Gymnoderma lineare) as occuring within Jackson County. As indicated in the Chinquapin Property Irrigation Supply Feasibility Analysis (EcoEngineering, August- 2008) an EcoEngineering A division of The John R. McAdams Company, Inc. February 1, 2010 Response to Comments TRL-08000 Page 4 initial stream habitat assessment was conducted. No fish, mussel, clam, or snail, species were observed at the time of these investigations. In addition, no federally protected species were observed during field investigations. However, potential habitat exists within Robison Creek for Appalachian elktoe. Therefore, Section 5a. was marked yes. Although formal consultation with the U.S. Fish and Wildlife Service has not been pursued, based on the initial stream habitat assessment it is anticipated that the proposed project is not likely to adversely affect designated Appalachian elktoe habitat. NCDENR - DWQ - Comments Dated June 14, 2009 Comment 1: No demonstration has been made in the application regarding the feasibility of alternatives to the pumping system (via drilling a deeper well, rainwater harvesting, or the use of reuse water on the golf course, or other means of water conservation). Response 1: The Chinquapin property which is approximately 1,926 acres utilizes Tulip Pond and a well as two irrigation options. Tulip Pond is the primary irrigation source used by the Chinquapin property. During years with normal precipitation events, water usage ranges from 40,000 to 150,000 gallons per day (averaging approximately 75,000 gallons per day). During drought periods, Tulip Pond does not satisfy the irrigation needs of the Chinquapin property and therefore supplemental options, such as a well are required. The well, which is approximately 1,000 feet deep, is a supplemental source used only during abnormally dry periods or drought years. During drought conditions, the supplemental well has a maximum daily water yield of 12,000 to 16,000 gallons per day and is required to be hauled by vehicle. During the years of 2007 and 2008, the mountain region was in a severe drought, causing great stress to groundwater supplies used as potable water sources in the region. The drought affected the Chinquapin property severely, drawing -MIFiftnFn ineering A division of The John R. McAdams Company, Inc. February 1, 2010 Response to Comments TRL-08000 Page 5 the water level of Tulip Pond down so much so that the pond was dry on June 13 and June 26, 2008 (attached Section 4 - Tulip Pond Water Withdrawal Rates). From June 14 to July 18, 2008 there were 19 times in which there was no irrigation from Tulip Pond. During that period, an average of 42,081 gallons per day was withdrawn from Tulip Pond, which is approximately 44% below normal water usage rates. The well, which withdrew water from an already stressed groundwater supply, was utilized to supplement irrigation needs of the Chinquapin property during the drought period. The supplemental water supply from the well brought the average gallons per day usage rate to 31% below normal water usage rates. Tulip Pond is an amenity to the Chinquapin property and the primary irrigation supply to the property. Tulip Pond is also the headwater source for many streams located on the Chinquapin property, including Packs Creek and Robinson Creek. Therefore, given the drought of 2007 and 2008, it is imperative to identify additional, sustainable, low impact water resources to be used for irrigation sources. Multiple alternatives to address the water needs of the Chinquapin property have been evaluated and are described below. Additional Well Construction: As stated above, currently there is one well located on the Chinquapin property which is used as a supplemental irrigation option. In 2008, three wells were drilled to a depth of 1,000 feet. Two. wells produced less than 4 gallons per minute and were deemed insufficient for irrigation supplementation. Only one well produced enough water suitable for potential irrigation purposes. The chosen well has a maximum daily yield of 12,000 to 16,000 gallons per day and requires the water to hauled by vehicle. Groundwater is a valuable asset within the mountain region, and any withdrawals from an existing well, especially during drought periods, affects the surrounding groundwater supply. Wells are not 100 percent reliable. Groundwater table elevations can change, leaving wells dry in a time of need. Although options such as drilling an additional well to supplement the irrigation supply have been explored, it is EcoEngineering A division of The John R. McAdams Company, Inc. February 1, 2010 Response to Comments TRL-08000 Page 6 with great reluctance that an additional well be used on the Chinquapin property considering the importance of the groundwater supply within the mountain region. Due to the concern of impacting the regional groundwater supply, it was determined an additional well used for irrigation purposes on the Chinquapin property is not the most prudent use of potable water. Therefore, other options have been explored. Water Conservation Options: Water application procedures which reduce run-off from the Chinquapin property have been implemented in an effort to conserve as much water as possible when irrigating from existing Tulip Pond and the well. Procedures such as an efficient pump system and varying irrigation periods have been instituted in the water application process. Options such as slow moisture meters are also currently being explored. Other water conservation options which have been examined are discussed below. a) Rainwater Harvesting Water conservation options such as rainwater harvesting storm water techniques were explored; however, approximately 95% of the Chinquapin property is undeveloped and due the limited impervious surfaces located on the property, this option would not provide the necessary yield to be an adequate supplemental source. b) Waste Water Re-use In addition, re-use of waste water was examined. The Chinquapin property currently discharges a limited amount of waste water. There are three full time employees, eight seasonal employees, and one part time resident located on the Chinquapin property. The potential yield from re-use of waste water would not be an adequate supplemental source. When examining water conservation options for the Chinquapin property and comparing the total potential yield, it has been determined that these efforts would not be EcoEngineering A division of The John R. McAdams Company, Inc. February 1, 2010 Response to Comments TRL-08000 Page 7 a suitable supplemental" source for the demands of the property. Therefore, other reliable water source options were examined. Off-line Pond Construction: Construction of an additional off-line pond (i.e. Tulip Pond 11) was examined. It was determined a 6.9 acre pond at a depth of 1 foot could potentially be constructed, yielding 150,000 gallons every other day during a 30 day period (i.e. averaging 75,000 gallons per day). If the depth of the pond was increased to 6 feet, then a 2.3 acre pond could potentially be constructed yielding similar results. Due to the topographic setting of the Chinquapin property, there are limited areas- in which an additional pond could be constructed. Suitable land for pond construction is located approximately 2,500 feet down gradient of existing Tulip Pond within an area designated as a conservation easement which is managed by the North American Land Trust (HALT). Deforestation within the conservation easement and risks associated with sedimentation downstream has been deemed unacceptable. The forested areas located on the Chinquapin property can be generally characterized as a Northern Hardwood Forest - Typic Subtype according to the Classification of Natural Communities of North Carolina (Schafle and Weakley, 1990). Although this is not a rare habitat community, the owner views the existing forested communities on the Chinquapin property as valuable resources. As such, large sections of the Chinquapin property have been placed within a conservation easement and are managed by the NALT. Approximately 702 acres of the Chinquapin property has been placed within conservation easements. Any tree removal associated with the construction of an additional off-line pond would be detrimental to the aesthetic beauty of the Chinquapin property and impact the existing conservation easement. In addition, clearing a mature natural forested community and changing it into an open lacustrine habitat would fragment existing terrestrial species which currently utilize the forested community. Furthermore, unnecessary increased sedimentation will result downstream during the construction of an off-line EcoEngineering A division of The John R. McAdams Company, Inc. February 1, 2010 Response to Comments TRL-08000 Page 8 pond, eventually affecting Packs Creek and Robinson Creek. In addition, sediment loads will continue to occur downstream_ after the construction of an off-line pond. The effects of increased sedimentation to more critical aquatic/stream habitats downstream could have a deleterious affect on aquatic organisms and their habitat, thereby affecting the quality of the stream. In addition, the geomorphology of streams could potentially be affected by increased sedimentation loads, ultimately affecting alignment and hydrologic capacity of downstream systems. As a consequence, construction of an off-line pond would have immediate terrestrial impacts in addition to immediate and long term aquatic impacts downstream. Pump Installation within Robinson Creek: As a result, an option which minimally impacts an existing reliable water source was examined. Two forms of pump installation within Robinson Creek have been examined. A suction lift centrifugal pump was examined. A centrifugal pump relies on very high rotations per minute to suction water. The centrifugal pump requires large amounts of energy to operate, emits high volumes of noise, and requires high levels of maintenance. The preferred option is the placement of a submersible pump which will be attached to a fabricated aluminum submersible sled and secured by cables to the banks of Robinson Creek (attached Section 2 - Figure 4 Inset 1). The submersible pump will be powered by a 25 horsepower, 460 volt, and 3 phase motor capable of pumping 100 gallons per minute at 390 feet of resistance. The. submersible pump requires less energy to operate than a centrifugal pump, emits less noise than a centrifugal pump, and maintenance of a submersible pump is relatively minimal. The submersible pump is 2.5 feet wide and 4.5 long and it contains an intake opening of 0.25 inches. The submersible pump is designed to allow safe passage of aquatic species. A hose will be extended from the submersible pump to existing Tulip Pond. The hose will generally be aligned adjacent to the existing wilderness trail. In areas where there is a large topographic break, the hose will cross the topographic break aerially. EcoEngineering A division of The John R. McAdams Company, Inc. February 1, 2010 Response to Comments TRL-08000 Page 9 Comment 2: The Division is unable to determine the impact to the stream from the information provided. Maximum pumping capacity (including pump sizing) and maximum predicted withdrawal should be provided, in addition to the 7Q 10s flow of the stream. Approval must be based on worse case conditions - which are maximum withdrawal under low flow stream conditions. Response 2: Maximum pump capacity is 100 gpm at 390 feet of pressure head. Predicted withdrawal is 52 gpm. The 7Q10 flows, provided by the Division of Water Resources, is 1.3 cubic feet per second. It was stated in DWQ comment two that "Approval must be based on worse case conditions - which are maximum withdrawal under low flow stream conditions." We have recommended that no pumping shall occur if the stream is at or below the 7Q10 flow. Comment 3: A scaled drawing should be provided indicating temporary impact, access to the stream and Tulip Pond (including Tulip Pond). Response 3: Attached in Section 2 are Figures 1 through 5 which show the location of the proposed submersible pump, location of the buffer to be temporarily removed, access to the stream, and Tulip Pond. No other fill and/or dredging impacts are anticipated for the proposed project. NCWRC - Comments Dated June 12, 2009 Comment 1: Flow data needs to be obtained from Robinson Creek and used to evaluate the effects of the withdrawal on aquatic habitat through coordination with Commission. and NCDENR, Division of Water Resources (DWR) staffs. Response 1: Flow data for Robinson Creek has been provided in the attached Section 1- Graphs and Data. Comment 2: Information about the pump and line design plan, and operational capacity need to be presented. Withdrawals of 100,000 gpd must be registered with DWR (see G.S., 143-215 EcoEngineering A division of The John R. McAdams Company, Inc. February 1, 2010 Response to Comments TRL-08000 Page 10 .22H), which may apply to this project. The existing 150,000 gpd withdrawal from Tulip Pond may be subject as well. Response 2: Responses are provided above to USACE comments dated June 29, 2009. Comment 3: Records showing daily water usage and availability from existing sources during the 2008 drought need to be evaluated to characterize the current supply deficiency, if applicable. Any alternatives to the withdrawal, such as on-site wastewater application, should be evaluated as well. Response 3: Attached are daily records showing daily water usage and availability of existing Tulip Pond (attached Section 4 - Tulip Pond Water Withdrawal Rates). During periods when Tulip Pond was not available for use, a well located on the Chinquapin property was utilized which yielded 12,000 to 16,000 gallons per day. This method of irrigation is not the preferred method due to concerns associated with groundwater table impacts. An alternative analysis is provided above in responses to NCDENR-DWQ comments dated June 14, 2009. Comment 4: A comprehensive operational, plan, withdrawal plan, stream flow monitoring and stream flow reporting schedule need to be prepared and implemented with any withdrawal. Response 4: An Operation and Maintenance- (O&M) Manual, which includes stream flow monitoring and reporting schedule, was prepared and submitted to the Chinquapin property on September 1, 2009. Sections of the O&M Manual include: Record keeping, stream gage data collection, gage manufacturer data, gage software, pump information, permits, and stream / pump records. EcoEngineering has recommended the permit condition 3 which states "Daily stream flow records shall be submitted on an annual basis. Daily withdrawal amounts shall also be submitted on an annual basis. This data shall be submitted with the annual submittal for Tulip Pond as required under Division of Water Resources G.S. 143-215.22H. EcoEngineering A division of The John R. McAdams Company, Inc. February 1, 2010 Response to Comments TRL-08000 Page 11 If you have any questions or require additional information, please do not hesitate to contact me at (919) 287-4262. Sincerely, A division of T R. MCADAMS COMPANY, INC. eor a Buchholz, REM, PWS Environmental Scientist Enclosures - Supporting Documentation Cc: David McHenry, NCWRC Susan A. Wilson, NCDWQ Cyndi Karoly, NCDWQ Kevin Barnett, NCDWQ SUPPORTING DOCUMENTS SECTION 1- GRAPHS & DATA • Summary • Jackson County Rainfall Data • Gage Data Graph • Cross Section Information • Rating Table; Flow vs. Depth • Rating Curve • September 2008 low flow stream measurement SECTION 2 - EXHIBITS • Figure I USGS Map • Figure 2 Vicinity Map • Figure 3 Existing Conditions • Figure 4 Inset 1 • Figure 5 Detail Sheet SECTION 3 - PRECONSTRUCTION NOTIFICATION • Revised PCN SECTION 4 - WATER WITHDRAWAL RATES • Tulip Pond Withdrawal Rates (May thru July, 2008) SECTION 5 - PROJECT HISTORY • USACE Action ID: 2006-30849-350 SECTION I - GRAPHS & DATA Irrigation Supply - Permit Application Re-submittal • Chinquapin Property Jackson County, North Carolina • TRL-08000 • January 2010 Gage Data Analysis and Summarv Data Analysis On August 31, 2009 Ecolingineering installed a differential pressure transducer (depth gage) at the proposed stream withdrawal location on the Chinquapin property. The gage is located approximately 100-feet downstream of the confluence of Packs Creek with Robinson Creek. A pressure transducer was also placed above ground nearby to measure atmospheric pressure which is used to calculate the depth of water at the gage. Data was collected during September and October and is presented in the Gage Data Graph located in this section. The mean stream depth was 1.63 feet. Precipitation data for the project area was obtained from rain gage records for a weather station located approximately 15 miles away from the site. This data is presented as Jackson County Rainfall Data and lists the monthly precipitation for 2007, 2008, and 2009. The stream's cross-section was surveyed at the gage using a total station and water surface and bed elevations were measured upstream and downstream of the proposed withdrawal location. Water surface elevations were used to evaluate slope, which was needed to develop a rating curve for the proposed with drawl location. The gage was installed in the thalweg of the stream adjacent to the surveyed cross. A Global Water flow probe (Model FP101) was used to measure stream velocity along the cross-section. This data was used to estimate a discharge rate of the stream as measured on August 31, 2009. At a depth of 1.66 feet, measurements indicated a discharge rate of 2.19 cubic feet per second. The average depth of the stream during September and October was 1.63 feet; therefore, it can be stated that the average flow within the creek was approximately 2 CFS. The cross-section and flow data information is presented in this section as Cross-Section Information. Survey data, field flow measurements, and field observations were used to generate the relationship between depth and flow (also called a rating curve). A hydraulics program developed by Haestead Methods Inc. (Flowmaster v6.0) was used to generate a rating curve for the stream withdrawal location. The surveyed cross-section was entered into the program, along with a Manning's roughness coefficient, and the measured stream slope. In- stream velocity measurements were also used in developing the Rating Table; Flow vs. Depth which is presented in this section. A graphical representation is located at the end of this Section and is titled Rating Curve. 1 ®EcoEngineering 2010-01-12 Summary of Gauge Data.doc Adivision of The Jolui R McAdams Company, Inc. Irrigation Supply - Permit Application Re-submittal • Chinquapin Property Jackson County, North Carolina • TRL-08000 • January 2010 Summary Field data and historical rainfall data indicate that the proposed withdrawal rate of 75,000 gallons per day is feasible and will not exceed 20 percent of the 7Q10 flow. Rainfall records show that 2007 and 2008 rainfall amounts were generally below normal. Stream flow measured on September 16, 2009 by Goldie and Associated was 1.55 CFS although the rainfall for September that year was only 0.7 inches - the lowest monthly observed rainfall during 2007, 2008, and 2009. The 7Q10 for the proposed withdrawal location is 1.3 CFS and was provided by Mr. Fred Tarver with the NC Division of Water Resources. As shown in the table below, 20% of 1.3 CFS is 168,000 GPD. The proposed withdrawal is 75,000 GPD which is 93,000 GPD less than the suggested allowable amount of 20 percent. Additionally, the data indicates that the fluctuation in flow between a "dry" year and a "wet" year is approximately 1,000,000 and 1,300,000 GPD. The proposed withdrawal rate is well below this range and well below 20 percent of the 7Q10. Summary Table - Section 1 Date / Description CFS GPD* September 2008 1.55 1,001,000 September 2009 1.95 1,260,000 October 2009 2.21 1,428,000 7Q10 1.3 840,000 Suggested allowable withdrawal (20% of 7Q10) 168,000 Proposed withdrawal (9% of 7Q 10) 75,000 1 CFS = 0.646; 1 MGD = 1.55 CFS *GPD rounded to the nearest thousand; GPD = gallon per day; CFS = cubic feet per second To address the concerns of the U.S. Army Corps of Engineers, NCDENR - DWQ Surface Water Protection Section, and the North Carolina Wildlife Resource Commission, EcoEngineering recommends the following permit conditions: 1. Withdrawal from Robinson Creek shall not exceed 75,000 gallons per day. The pumping rate shall not exceed 52 gallons per minute. (52 gpm x 60 min. x 24 hrs. = 74,880 gallons per day.) 2. Pumping shall not occur if stream discharge is at or below the stated 7Q10 level of 1.3 CFS which corresponds to a gauge depth of 1.42 feet at the current cross-section location and gage installed during Fall 2009. 3. Daily stream flow records shall be submitted on an annual basis. Daily withdrawal amounts shall also be submitted on an annual basis. This data shall be submitted with the annual submittal for Tulip Pond as required under Division of Water Resources G.S. 143-215 .22H. R=A EcoEngineering 2010-01-12 Summery of Gauge Data.doc 2 A &kiun of The John R. MoAda is Company, Inc. Robinson Creek near confluence Section 1 J. Halley, P.E. of Packs Creek; Chinquapin 1-12-10 Property; Jackson County Jackson County Rainfall Data TRL-08000 Jackson County Historical Rain Fall Data Station ID 3122000, Type-COOP Location: Cullowhee (approx. 15 miles from project location) Lattitude: 35.32556 Longitude: -83.19111 Period of Record for Normal rainfall 12/1/1909 to 1/6/2010 Rainfall Normal above or Measured Month-Year below 7Q10 (CFS) Remark (in) rainfall (in) (CFS) flow normals Jan-07 4.72 4.92 below Feb-07 3.28 4.69 below Mar-07 3.14 5.43 below Apr-07 1.92 3.91 below May-07 0.88 4.86 below Jun-07 6.75 4.34 above Jul-07 9.44 4.27 above Aug-07 4.52 3.91 above Sep-07 4.90 3.57 above Oct-07 2.34 3.2 below Nov-07 2.74 4.28 below Dec-07 4.58 4.33 above Totals 49.21 51.7 below Annual rainfall below normal. Jan-08 3.51 4.92 below Feb-08 4.51 4.69 below Mar-08 7.46 5.43 above Apr-08 3.30 3.91 below May-08 2.32 4.86 below Jun-08 1.62 4.34 below Jul-08 5.06 4.27 above Aug-08 5.43 3.91 above Sep-08 0.70 3.57 below 1.55 1.3 Lowest monthly rainfall in 3 yrs. Oct-08 1.43 3.2 below Nov-08 3.11 4.28 below Dec-08 6.24 4.33 above Totals 44.69 51.7 below Annual rainfall below normal. Jan-09 4.75 4.92 below Feb-09 2.93 4.69 below Mar-09 4.42 5.43 below Apr-09 4.14 3.91 above May-09 8.97 4.86 above Jun-09 3.38 4.34 below Jul-09 3.87 4.27 below Aug-09 3.63 3.91 below Sep-09 10.58 3.57 above 1.95 1.3 Oct-09 6.18 3.2 above 2.21 1.3 Nov-09 5.28 4.28 above Dec-09 8.88 4.33 above Totals 67.01 51.7 above Annual rainfall above normal. Rainfall Data: http://www.nc-climate.nesu.edu/dynainic-scripts/cronos/query.php Normals Data: http://www.nc-climate.nesu.edu/cronos/normals.php?station=312200 7Q10 Data: 7Q10 flow for the gage location was obtained from Mr. Fred Tarver with the Division or Water Resources, Drainage area 1372 acres (2.14 square miles), obtained on 5-11-07. 2010-01-12 Section 1 InsertAs Jackson Co. Rain Data .tea ??? ? o N_ q c C q ? y ., o 0 ?A A A ~~ A I--F? I-H ¦ vii ? y I-¦-? ?w y II M N yi 0 N ? '? II I? II CA U M N N -+ -+ O O 60 600 11 6 1F/ 00/6 0/ 190 0/ 000/ 6 Obe 01 00 01, 00/6t 01 60 ve, 01 t 190 0/ t 60ve, 0I l 600 /0l /ll 600/ /0l 600 01 600 01 600 /Ol /el/ 600 01 v/l 0,9 /Ol 60 ?i6 oe- 6O O1 F , 60 --6 02/ 60 `^2/6 Off/ 00 600 6 600 lib 600 lib 2/F 60O lib e Ile -6-6- (;j) q;dap [uuaa;S Robinson Creek near confluence Section 1 J. Halley, P.E. of Packs Creek; Chinquapin 1-12-10 Property; Jackson County Cross-Section Information TRL-08000 Cross-Section at Gage; see Figure 4 for gage location 3695 3694 3693 3692 3691 3690- S 3689 0 3688 3687 w 3686 3685 - 3684 3683 6 2 3 8 3681 3680 0 5 10 15 20 25 30 35 Width from River Left to Right (ft) Survey Data (collected 8/31/09) Description Elevation Station (from survey pin; river left) Water Depth (ft) GRPIN 3690.88 0.0 na GROUND 3690.70 0.9 na GROUND 3690.62 1.7 na GROUND 3689.11 7.1 na GROUND 3688.52 8.0 na STRMBED 3687.09 7.9 0.58 STRMBED 3686.01 8.6 = 2.19 CFS at this depth) 1.66 STRMBED 3686.77 9.4 0.90 STRMBED 3687.11 10.8 0.55 WTRSURF 3687.66 12.2 na GROUND 3687.97 14.9 na GROUND 3689.26 21,8 na PIN 3692.86 29.8 na Note: Gage located adjacent to cross-section in deepest part of stream (thalweg). Flow Data: field measured by EcoEneineerine on 8/31/09 (Global Water Flow Probe Model FP101: S/N 091794672) Field Data Field Data Computations Section mid Section Average Cross-section Width of section Section Depth Average Section point (ft) depth (ft) Velocity survey station measurement (ft) Velocity (ft/s) Discharge, Q (CFS ft/S ) n/a n/a n/a 7.94 n/a 0 0 n/a 8.2 0.6 0.7 8.2 0.3 0.6 0.67 0.026 8.8 1.7 0.8 8.8 0.6 1.7 0.79 0.493 9.2 1.3 0.4 9.2 0.4 1.3 0.36 0.342 10.2 0.8 0.1 10.2 1.0 0.8 0.13 0.258 11.2 0.6 1.5 11.2 1.0 0.6 1.46 0.545 12.0 0.2 1.0 12.0 0.8 0.2 1.01 0.385 n/a n/a n/a 14.87 2.87 0 0 0.145 (Based on cross-section stationing) Total Q = 2.19 2010-01-12 Section I Insert.xls Cross-Section Information Robinson Creek near confluence Section 1 of Packs Creek; Chinquapin Property; Jackson County Rating Table; Flow vs. Depth TRL-08000 Flow (Discharge) J. Halley, P.E. 1-12-10 Depth at gage (ft) CFS feet per second) (cubic GPD (gallons MGD per day) (million gallons per day) - 0 0 0 0.60 0.09 0.00 212 0.00 _ 0.19 0.00 2,246 0.00 0.29 0.01 4,492 0.00 0.39 0.02 11,231 0.01 0.49 0.03 20,216 0.02 0.59 0.05 31,447 0.03 0.69 0.08 49,417 0.05 0.79 0.10 67,387 0.07 0.89 0.15 98,835 0.10 0.99 0.25 159,483 0.16 1.09 0.39 253,825 0.25 1.19 0.62 397,584 0.40 1.29 0.89 572,791 0.57 1.39 1.20 774,953 0.77 _ 1.49 1.55 1,004,069 1.00 1.59 1.95 1,262,387 1.26 _ 1.69 2.32 1,502,735 1.50 1.79 _ 2.70 1,743,082 1.74 1.89 3.19 2,064,295 2.06 1.99 3.85 2,491,080 _ 2.49 2.09 4.70 3,036,916 3.04 2.19 2.29 5.65 6.72 3,652,386 4,341,982 3.65 4.34 2.39 7.90 5,107,950 5.11 2.49 9.21 5,952,536 5.95 _ 2.59 10.61 6,860,017 6.86 2.69 12.16 _ 7,859,594 7.86 2.79 13.87 8,964,744 8.96 2.89 15.75 10,179,960 10.18 2.99 17.81 11,509,734 11.51 3.09 20.04 12,956,312 12.96 3.19 22.37 14,461,293 14.46 3.29 25.01 16,166,189 16.17 3.39 28.00 _ 18,100,202 18.10 3.49 31.19 20,160,004 20.16 Mannines n: 0.062; Rosgen B2 stream type Water suface slope: 0.024 (2.4%) Flowmaster v6.0 by Haestead Methods. 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September 18, 2008 Mr. Lee Howc Trillium Links / Chinquapin One Trillium Center Cashiers, NC 28717 Re: Stream Flow Monitoring Data Goldie Project No. 1312.1 Dear Mr. Howe: GOLDIE ASSOCIATES engineering, environmental and laboratory services Please find enclosed the above referenced flow monitoring data as conducted by Goldie and Associates on September 16, 2008 for the Packs Creek location on the Chinquapin property. Flow was recorded using a Global Water FP-101 Flow Probe, measuring feet per second (ft/s) flows across the designated channel at one foot width intervals. We have enclosed maps indicating the location of the sampling, a cross sectional diagram of the channel, and the field measured and tabulated total flow data; total daily flow was calculated to be 1.00 million gallons per day (MGD). Additionally, please note that the stream was noted to be in relative low flow conditions as the ordinary high water mark (OHWM) was noted to be several inches higher than the current top of water. We appreciate this opportunity to serve; please contact us if you have questions or require additional information. Sincerely, Goldie and Associates Ben S. Day Environmental Manager / Wetlands Scientist encl: As stated 210 W North Second Street ® Seneca, South Carolina 29678 0 Phone (864) 882-8194 a Fax (864) 882-0851 Chinquapin - Packs Creek Flow Data Goidie Project 1312.1 Date Time 9/16/2008 11:00 AM Sample Pt Distance * -13Fpfffi-F (ft) -751ocity (ftls) *"- egmen Width,(ft) Flow (ft"3/s) 1 ow (9411on/9) ow (MGD) 1 ! 0.5 0.40 0.01 I 1 0 00 I 0.03 ; 0.00 2 -5, 1 .1 0 60 ; 0.01 I 1 . 0.01 0.04 ! 0 00 3 2.5 0.75 ; 0.01 j 1 0.01 0.06 ! 0 00 4 ' 3.5 0.69 ; 0.16 ! 1 0.11 0.83 i 0 07 5 i 4.5 0 68 0.29 ? 1 0.20 ! 1.48 0.13 6 5.5 6.66 0.55 f 1 0.28 2.06 t 0.18 7 6.5 0.50 0.71 1 .. 6.36 { 2.66 j 0.23 8 7.5 0 40 0.68 1 0.27 i 2.03 0.18 9 8.5 . 30 I . 6.3'0-" . 0.76 1 1 b.23' I , 9.71 0.15 10 9.5 0.25 1 0.38 I 1 0.10 1 0.71 0.06 " Stream width: 10 ft; each sample pt at mid point of 1 ft increments across width ** Average speed over 40 seconds at approximately 6/10ths segment depth *** Million Gallons per Day (gallons/s x 3600s x 24hr = 10^6) SECTION 2 - EXHIBITS PROJECT NO. TRL-08000 RECONSTRUCTION ftoEngineering 9 FILENAME: TRL08000-X.DWG NOTIFICATION A A division of The John R. McAdams Company Inc SCALE: " ' , . > = 5 1 000 , CHINQUAPIN IRRIGATION SUPPLY PROJECT RESEARCH TRIANGLE PARK NC U] GATE; 12-04-2009 JACKSON COUNTY, NORTH CAROLINA , (919)e361 5000 ZIP 27709-A005 'PROPOSED A ER SUPPLY LINE TULIP POND GRAPHIC SCALE Z 1500 O 0 750 1500 3000 TnMenM F IGURE 2. VICINITY MAP x e 1 inch = 1500 ft. PROJECT No. TRL-08000 FIGURE 2 E FILENAME: iRL09000-X.OV1?C SIT A division of The John R McAdams I G7 SCALE: ' „ E DRAINAGE AREA nc. - 1,500 1 CHINQUAPIN IRRIGATI RESEARCH TRIANGLE PARK NC ON FEASIBILITY ANALYSIS , I/j DATE: 12-04-2009 JACKSON COUNTY, NORTH CAROLINA (919)8301-5000 ZIP 27709-4005 08000 RE_CONSTRUCTIO [4EcoEngineering ( .DWG EN A diwiam of lbe JoL NOTIFICATION PARK NC CHINQ UAPIN IRRIGATION SUPPLY PROJECT P O , BOX lpOg 21 4005 ZIP P O BOX 27709 005 09 JACKSON COUNTY, NORTH CAROLINA . . . . - (919) 361-5000 PROJECT FILENAME: NO. TRL-08000 RECONSTRUCTION F4fEcoEngineering TRL08000-X.DWG NOTIFICATION A division of The John I. McAdams Company. Inc. a SCALE: - 30' 4 CHINQUAPIN IRRIGATION SUPPLY PROJECT RESEARCH TRIANGLE PARK, NC N DATE: 12-04-2009 JACKSON COUNTY, NORTH CAROLINA (9119)H38115000 ZIP 27709-4005 PLAN VIEW NOT TO SCALE ANCHORING CABLE FLOW DIRECTION TEMPORARY IMPACT AREA PUMP OUTLET PIPE TOP OF BANK SCREEN/WATER INTAKE PUMP RESTS DIRECTLY ON STREAM BED TEMPORARY ACCESS ENTRANCE; 6 FOOT WIDE; SOFT STREAM BANK PERPENDICULAR TO BUFFER AND STREAM; WILL BE SEEDED STABILIZATION TECHNIQUES WITHIN 10 DAYS OF INSTALLATION AND NOT MAINTAINED OVER THE TOP OF BANK PROFILE VIEW NOT TO SCALE SCREEN/WATER INTAKE; APPROXIMATELY 0.255INC DIAMETER OHW FLOW DIRECTION OUTLET PIPE i( )C7( }L?( )t )C 7(?C5?)C7(?C??WEIGHT OF PUMP KEEPS IT °<' ?-y fix' C. 16 '? ?° ?`????SUBMERGED AND STATIONARY BOULDER/COBBLE STREAM BED NOTE: PUMP INSTALLATION IS A WATER DEPENDENT ACTIVITY WITH DIMINIMUS INCREASES IN IMPERVIOUS SURFACES WHICH WILL ALLOW LOW FLOW PASSAGE OF WATER AND AQUATIC LIFE. FIGURE 5. DETAIL SHEET RL-08000 RECONSTRUCTION E I-08000-X.OWG V NOTIFICATION A division of The John R. McAdams Company, Inc. N.T.S. CHINQUAPIN IRRIGATION SUPPLY PROJECT R ESARC TRIANGLE PARK, C B H - AT -04-2009 JACKSON COUNTY, NORTH CAROLINA O. BOX 140 5 Z P 27 09 4005 (919) 361-5000 SECTION 3 - PRECONSTRUCTION NOTIFICATION 09 - 05LOq U a' of VATF9 -1 Office Use Only: Corps action ID no. DWQ project no. Form Version 1.3 Dec 10 2008 Pre-Construction Notification (PCN) Form A. Applicant Information SPAID 1. Processing I a. Type(s) of approval sought from the Corps: X Section 404 Permit ? Section 10 Permit 1 b. Specify Nationwide Permit (NWP) number: 18 or General Permit (GP) number: 1c. Has the NWP or GP number been verified by the Corps? ? Yes X No 1d. Type(s) of approval sought from the DWQ (check all that apply): X 401 Water Quality Certification - Regular ? Non-404 Jurisdictional General Permit ? 401 Water Quality Certification - Express ? Riparian Buffer Authorization le. Is this notification solely for the record because written approval is not required? For the record only for DWQ 401 Certification: ? Yes X No For the record only for Corps Permit: ? Yes X No If. Is payment into a mitigation bank or in-lieu fee program proposed for mitigation of impacts? If so, attach the acceptance letter from mitigation bank or in-lieu fee program. ? Yes X No 1g. Is the project located in any of NC's twenty coastal counties. If yes, answer 1 h below. ? Yes X No 1h. Is the project located within a NC DCM Area of Environmental Concern (AEC)? ? Yes X No 2. Project Information 2a. Name of project: Chinquapin Irrigation Supply Project 2b. County: Jackson 2c. Nearest municipality / town: Cashiers " 2d. Subdivision name: UL1 2e. NCDOT only, T.I.P. or state project no: ZQi? S TERQUAL" 3. Owner Information U?T(gHp$ AID 3a. Name(s) on Recorded Deed: Patrick E. Carlton, Trustee 3b. Deed Book and Page No. DB 468 PG 139 3c. Responsible Party (for LLC if applicable): Patrick Carlton 3d. Street address: P.O. Box 2128 3e. City, state, zip: Cashiers, NC 28717 3f. Telephone no. (828)508-6536 3g. Fax no.: 3h. Email address: Page 1 of 14 PCN Form - Version 1.3 December 10, 2008 Version 4. Applicant Information (if different from owner) 4a. Applicant is: ? Agent ? Other, specify: 4b. Name: 4c. Business name (if applicable): 4d. Street address: 4e. City, state, zip: 4f. Telephone no.: 4g. Fax no.: 4h. Email address: 5. Agent/Consultant Information (if applicable) 5a. Name: George Buchholz, REM, PWS 5b. Business name (if applicable): EcoEngineering, A division of The John R. McAdams Company 5c. Street address: 2905 Meridian Parkway 5d. City, state, zip: Durham, NC 27713 5e. Telephone no.: 919-361-5000 5f. Fax no.: 919-361-2269 5g. Email address: buchholz@ecoengr.com Page 2 of 14 B. Project Information and Prior Project History 1. Property Identification 1 a. Property identification no. (tax PIN or parcel ID): 7584-42-5248 & 7584-83-0394 1 b. Site coordinates (in decimal degrees): Latitude: 35.1796536 Longitude: - 83.0667794 (DD.DDDDDD) (-DD.DDDDDD) 1 c. Property size: 1,282 acres in total 2. Surface Waters 2a. Name of nearest body of water (stream, river, etc.) to Robinson Creek proposed project: 2b. Water Quality Classification of nearest receiving water: WS-III; TR 2c. River basin: Little Tennessee (HUC 06010203); DWQ Stream Index # 2-79-13 3. Project Description 3a. Describe the existing conditions on the site and the general land use in the vicinity of the project at the time of this application: The project is located within the Chinquapin property which is a golf course and the surrounding area is primarily forested with limited residential uses within the vicinity. The project site, itself, is located within a forested community which could be classified as Northern Hardwood Forest - Typic Subtype according to the Classification of the Natural Communities of North Carolina (Schafale and Weakley, 1990). Robinson Creek contains areas which are as wide as 40-feet wide; however, on average the stream is approximately 20-feet wide. Water depths within riffles areas range from 3 to 7-inches deep and within pools 2 to 3.5-feet deep. 3b. List the total estimated acreage of all existing wetlands on the property: 0.0 acres within the project site; a complete jurisdictional wetland delineation has not been performed for the entire 1,926 acre Chinquapin property. 3c. List the total estimated linear feet of all existing streams (intermittent and perennial) on the property: Approximately 1,500 feet was evaluated as part of the Irrigation Supply Feasibility Analysis (EcoEngineering, 2008) 3d. Explain the purpose of the proposed project: The purpose of the project is to construct an irrigation supply system within Robinson Creek for water withdrawal purposes. Withdrawal from Robinson Creek will be used to supplement and maintain pool level in Tulip Pond during abnormal) d periods or drought conditions. Tulip Pond is the existing reservoir for the property's irrigation supply. 3e. Describe the overall project in detail, including the type of equipment to be used: The project will involve the installation of a submersible pump system within Robinson Creek. Use of hand tools and a small bobcat will be used with limited clearing to gain access to Robinson Creek. The submersible pump will be powered by a 25 horsepower, 460 volt, and 3 phase motor capable of pumping 100 gallons per minute at 390 feet of resistance. The submersible pump is 2.5 feet wide and 4.5 long and it contains an intake opening of 0.25 inches. The submersible pump will be attached to a custom fabricated aluminum submersible sled (approximately 3 feet wide and 5 feet long). The sled will be anchored by two cables stretched up stream and staked in the banks (see attached Detail Sheet, Figure 5). The submersible um and sled assemblage, which weighs approximately 500 pounds, will sink to the bottom of the stream. 4. Jurisdictional Determinations 4a. Have jurisdictional wetland or stream determinations by the Corps or State been requested or obtained for this property / ? Yes X No ? Unknown project (including all prior phases) in the past? Comments: 4b. If the Corps made the jurisdictional determination, what type ? Preliminary ? Final of determination was made? 4c. If yes, who delineated the jurisdictional areas? Agency/Consultant Company: EcoEngineering, A division Name (if known): of The John R. McAdams Company, Inc. Other: 4d. If yes, list the dates of the Corps jurisdictional determinations or State determinations and attach documentation. Page 3 of 14 PCN Form - Version 1.3 December 10, 2008 Version B. Project Information and Prior Project History 5. Project History 5a. Have permits or certifications been requested or obtained for X Yes ?No ? Unknown this project (including all prior phases) in the past? 5b. If yes, explain in detail according to "help file" instructions. • A PCN application requesting authorization under NWP 18 to install a submersible pump system within Robinson Creek was submitted on May 13, 2009 for the Chinquapin Irrigation Supply Project. • A NWP 12, 29, and 33 was issued on July 9, 2007 (Action ID: 2006-30849-350, attached Section 5) 6. Future Project Plans 6a. Is this a phased project? ? Yes X No 6b. If yes, explain. Page 4 of 14 C. Proposed Impacts Inventory 1. Impacts Summary 1 a. Which sections were completed below for your project (check all that apply): ? Wetlands X Streams - tributaries ? Buffers ? Open Waters ? Pond Construction 2. Wetland Impacts If there are wetland impacts proposed on the site, then complete this question for each wetland area impacted. 2a. 2b. 2c. 2d. 2e. 2f. Wetland impact Type of jurisdiction number - Type of impact Type of wetland Forested (Corps - 404, 10 Area of impact Permanent (P) or (if known) DWQ - non-404, other) (acres) Temporary T NONE ? Yes ? Corps ? No ? DWQ 2g. Total wetland impacts 2h. Comments: 3. Stream Impacts If there are perennial or intermittent stream impacts (including temporary impacts) proposed on the site, then complete this question for all stream sites impacted. 3a. 3b. 3c. 3d. 3e. 3f. 3g. Stream impact Type of impact Stream name Perennial Type of jurisdiction Average Impact number - (PER) or (Corps - 404, 10 stream length Permanent (P) or intermittent DWQ - non-404, width (linear Temporary (T) (INT)? other) (feet) feet) S1 X P ? T Dredge/Fill Robinson Creek X PER X Corps 20 5 ? INT X DWQ S1 ? P X T Construction Robinson Creek X PER X Corps 20 15 Access ? INT X DWQ 3h. Total stream and tributary impacts 20 3i. Comments: There will be a total of 5 linear feet and 15 square feet of permanent stream impacts and 15 linear feet and 135 square feet of temporary impacts associated with the construction of the pump. There will be a total of 5 cubic yards of ermanent fill within the stream associated with the pump. 4. Open Water Impacts If there are proposed impacts to lakes, ponds, estuaries, tributaries, sounds, the Atlantic Ocean, or any other open water of the U.S. then individual) list all open water impacts below. 4a. 4b. 4c. 4d. 4e. Open water Name of waterbody impact number - (if applicable) Type of impact Waterbody type Area of impact (acres) Permanent (P) or Temporary T NONE 4f. Total open water impacts 4g. Comments: 5. Pond or Lake Construction If and or lake construction proposed, then complete the chart below. Page 5 of 14 PCN Form - Version 1.3 December 10, 2008 Version 5a. 5b. 5c. 5d. 5e. Wetland Impacts (acres) Stream Impacts (feet) Upland Pond ID Proposed use or purpose (acres) number of pond Flooded Filled Excavated Flooded Filled Excavated Flooded P1 NONE P2 5f. Total 5g. Comments: 5h. Is a dam high hazard permit required? ? Yes ? No If yes, permit ID no: 51. Expected pond surface area (acres): 5j. Size of pond watershed (acres): 5k. Method of construction: 6. Buffer Impacts (for DWQ) If project will impact a protected riparian buffer, then complete the chart below. If yes, then individually list all buffer impacts below. If an impacts require mitigation, then you MUST fill out Section D of this form. 6a. ? Neuse ? Tar-Pamlico X Other: Trout Buffers Project is in which protected basin? Little Tennessee ? Catawba ? Randleman 6b. 6c. 6d. 6e. 6f. 6g. Buffer impact number - Reason Buffer Zone 1 impact Zone 2 impact Permanent (P) or for Stream name mitigation (square feet) (square feet) Temporary T im act required? 61 ? P X T Access to Robinson Creek ? Yes 108 0 stream X No B2 ?P?T ?Yes ? No B3 ? P ? T ? Yes ? No 6h. Total buffer impacts 108 0 61. Comments: A 6 foot wide temporary access entrance aligned perpendicularly to Robinson Creek will impact the 25 foot Trout Water riparian buffer. The temporary access entrance will be seeded within 10 days of installation and will not be maintained. Therefore, approximately 108 square feet of Trout Water Riparian Buffers will be temporarily impacted associated with the installation of the water withdrawal um system. Page 6 of 14 D. Impact Justification and Mitigation 1. Avoidance and Minimization Page 7 of 14 1 a. Specifically describe measures taken to avoid or minimize the proposed impacts in designing project. The Chinquapin property which is approximately 1,926 acres utilizes Tulip Pond and a well as two irrigation options. Tulip Pond is the primary irrigation source used by the Chinquapin property. During years with normal precipitation events, water usage ranges from 40,000 to 150,000 gallons per day (averaging approximately 75,000 gallons per day). During drought periods, Tulip Pond does not satisfy the irrigation needs of the Chinquapin property and therefore supplemental options, such as a well are required. The well, which is approximately 1,000 feet deep, is a supplemental source used only during abnormally dry periods or drought years. During drought conditions, the supplemental well has a maximum daily water yield of 12,000 to 16,000 gallons per day and is required to be hauled by vehicle. During the years of 2007 and 2008, the mountain region was in a severe drought, causing great stress to groundwater supplies used as potable water sources in the region. The drought affected the Chinquapin property severely, drawing the water level of Tulip Pond down so much so that the pond was dry on June 13 and June 26, 2008 (see attached May through July Water Records for 2008). From June 14 to July 18, 2008 there were 19 times in which there was no irrigation from Tulip Pond. During that period, an average of 42,081 gallons per day was withdrawn from Tulip Pond, which is approximately 44% below normal water usage rates. The well, which withdrew water from an already stressed groundwater supply, was utilized to supplement irrigation needs of the Chinquapin property during the drought period. The supplemental water supply from the well brought the average gallons per day usage rate to 31 % below normal water usage rates. Tulip Pond is an amenity to the Chinquapin property and the primary irrigation supply to the property. Tulip Pond is also the headwater source for many streams located on the Chinquapin property, including Packs Creek and Robinson Creek. Therefore, given the drought of 2007 and 2008, it is imperative to identify additional, sustainable, low impact water resources to be used for irrigation sources. Multiple alternatives to address the water needs of the Chinquapin property have been evaluated and are described below. Additional Well Construction: As stated above, currently there is one well located on the Chinquapin property which is used as a supplemental irrigation option. In 2008, three wells were drilled to a depth of 1,000 feet. Two wells produced less than 4 gallons per minute and were deemed insufficient for irrigation supplementation. Only one well produced enough water suitable for potential irrigation purposes. The chosen well has a maximum daily yield of 12,000 to 16,000 gallons per day and requires the water to hauled by vehicle. Groundwater is a valuable asset within the mountain region, and any withdrawals from an existing well, especially during drought periods, affects the surrounding groundwater supply. Wells are not 100 percent reliable. Groundwater table elevations can change, leaving wells dry in a time of need. Although options such as drilling an additional well to supplement the irrigation supply have been explored, it is with great reluctance that an additional well be used on the Chinquapin property considering the importance of the groundwater supply within the mountain region. Due to the concern of impacting the regional groundwater supply, it was determined an additional well used for irrigation purposes on the Chinquapin property is not the most prudent use of potable water. Therefore, other options have been explored. Water Conservation Options: Water application procedures which reduce run-off from the Chinquapin property have been implemented in an effort to conserve as much water as possible when irrigating from existing Tulip Pond and the well. Procedures such as an efficient pump system and varying irrigation periods have been instituted in the water application process. Options such as slow moisture meters are also currently being explored. Other water conservation options which have been examined are discussed below. a) Rainwater Harvesting Water conservation options such as rainwater harvesting storm water techniques were explored; however, approximately 95% of the Chinquapin property is undeveloped and due the limited impervious surfaces located on the property, this option would not provide the necessary yield to be an adequate supplemental source. b) Waster Water Re-use In addition, re-use of waste water was examined. The Chinquapin property currently discharges a limited amount of waste water. There are three full time employees, eight seasonal employees, and one part time resident located on the Chinquapin property. The potential yield from re-use of waste water would not be an adequate supplemental source. When examining water conservation options for the Chinquapin property and comparing the total potential yield, it has been determined that these efforts would not be a suitable supplemental source for the demands of the property. Therefore, other reliable water source options were examined. Off-line Pond Construction: Construction of an additional off-line pond (i.e. Tulip Pond II) was examined. It was determined a 6.9 acre pond at a depth of 1 foot could potentially be constructed, yielding 150,000 gallons every other day during a 30 day period (i.e. averaging 75,000 gallons per day). If the depth of the pond was increased to 6 feet, then a 2.3 acre pond could potentially be constructed yielding similar results. Due to the topographic setting of the Chinquapin property, there are limited areas in which an additional pond could be constructed. Suitable land for pond construction is located approximately 2,500 feet down gradient of existing Tulip Pond within an area designated as a conservation easement which is managed by the North American Land Trust (NALT). Deforestation within the conservation easement and risks associated with sedimentation downstream has been deemed unacceptable. Page 8 of 14 The forested areas located on the Chinquapin property can be generally characterized as a Northern Hardwood Forest - Typic Subtype according to the Classification of Natural Communities of North Carolina (Schafle and Weakley, 1990). Although this is not a rare habitat community, the owner views the existing forested communities on the Chinquapin property as valuable resources. As such, large sections of the Chinquapin property have been placed within a conservation easement and are managed by the NALT. A proximately 702 acres of the Chin ert ua in ro has been lac d withi ti t A p y q p p p p e n conserva on easemen s. ny tree removal associated with the construction of an additional off-line pond would be detrimental to the aesthetic beauty of the Chinquapin property and impact the existing conservation easement. In addition, clearing a mature natural forested community and changing it Into an open lacustrine habitat would fragment existing terrestrial species which currently utilize the forested community. Furthermore, unnecessary increased sedimentation will result downstream during the construction of an off-line pond, eventually affecting Packs Creek and Robinson Creek. In addition, sediment loads will continue to occur downstream after the construction of an off-line pond. The effects of increased sedimentation to more critical aquatic/stream habitats downstream could have a deleterious affect on aquatic organisms and their habitat, thereby affecting the quality of the stream. In addition, the geomorphology of streams could potentiall be affected b increased sedim t ti l d lti l t ff i li y y en a on oa s, u ma e y a ect ng a gnment and hydrologic capacity of downstream systems. As a consequence, construction of an off-line pond would have immediate terrestrial impacts in addition to immediate and long term aquatic impacts downstream. Pump Installation within Robinson Creek: As a result, an option which minimally impacts an existing reliable water source was examined. Two forms of pump installation within Robinson Creek have been examined. A suction lift centrifugal pump was examined. A centrifugal pump relies on very high rotations per minute to suction water. The centrifugal pump requires large amounts of energy to operate, emits high volumes of noise, and requires high levels of maintenance. The preferred option is the placement of a submersible pump which will be attached to a fabricated aluminum submersible sled and secured by cables to the banks of Robinson Creek (see attached Inset 1, Figure 4). The submersible pump will be powered by a 25 horsepower, 460 volt, and 3 phase motor capable of pumping 100 gallons per minute at 390 feet of resistance. The submersible pump i l t requ res ess energy o operate than a centrifugal pump, emits less noise than a centrifugal pump, and maintenance of a submersible pump is relatively minimal. The submersible pump is 2.5 feet wide and 4.5 long and it contains an intake opening of 0.25 inches. The submersible pump is designed to allow safe passage of aquatic species. A hose will be extended from the submersible pump to existing Tulip Pond. The hose will generally be aligned adjacent to the existin wilderness trail In r h th i l g . a eas w ere ere s a arge topographic break, the hose will cross the topographic break aerially. 1 b. Specifically describe measures taken to avoid or minimize the proposed impacts through construction techniques. Within Robinson Creek, the proposed location of the irrigation pump system will be placed within an upstream section which avoids wetlands and minimizes potential hydrologic impacts to wetlands which may be located downstream along Robinson Creek. The proposed location is also conducive in maintaining the natural flow variability of the stream; therefore, adverse effects of water withdrawal are not expected to impact species which require specific riffle and pool habitats. The proposed pump installation will allow low flow passage of water and aquatic life. Installation of the water withdrawal pump system will be conducted in accordance with sediment and erosion control requirements contained within the NC Design Standards in Sensitive Waters. During the installation of the water withdrawal pump system, temporary stream impacts will likely occur. These impacts primarily include increased sediment from the temporary disturbance of the stream bed. These impacts are not expected to create a significant adverse effect on the stream habitat because installation will be completed in a short amount of time and disturbance will be minimized. Installation of the water withdrawal pump system will be scheduled during low flow periods. 2. Compensatory Mitigation for Impacts to Waters of the U.S. or Waters of the State 2a. Does the project require Compensatory Mitigation for ? Yes X No impacts to Waters of the U.S. or Waters of the State? 2b. If yes, mitigation is required by (check all that apply): ? DWQ ? Corps ? Mitigation bank 2c. If yes, which mitigation option will be used for this project? ? Payment to in-lieu fee program ? Permittee Responsible Mitigation 3. Complete if Using a Mitigation Bank 3a. Name of Mitigation Bank: 3b. Credits Purchased (attach receipt and letter) Type Quantity Page 9 of 14 3c. Comments: 4. Complete if Making a Payment to In-lieu Fee Program 4a. Approval letter from in-lieu fee program is attached. ? Yes 4b. Stream mitigation requested: linear feet 4c. If using stream mitigation, stream temperature: ? warm ? cool ?cold 4d. Buffer mitigation requested (DWQ only): square feet 4e. Riparian wetland mitigation requested: acres 4f. Non-riparian wetland mitigation requested: acres 4g. Coastal (tidal) wetland mitigation requested: acres 4h. Comments: 5. Complete if Using a Permittee Responsible Mitigation Plan 5a. If using a permittee responsible mitigation plan, provide a description of the proposed mitigation plan. 6. Buffer Mitigation (State Regulated Riparian Buffer Rules) - required by DWQ 6a. Will the project result in an impact within a protected riparian buffer that requires buffer mitigation? ? Yes X No 6b. If yes, then identify the square feet of impact to each zone of the riparian buffer that requires mitigation. Calculate the amount of mitigation required. Zone 6c. Reason for impact 6d. Total impact (square feet) Multiplier 6e. Required mitigation (square feet) Zone 1 3 (2 for Catawba) Zone 2 1.5 6f. Total buffer mitigation required: 6g. If buffer mitigation is required, discuss what type of mitigation is proposed (e.g., payment to private mitigation bank, permittee responsible riparian buffer restoration, payment into an approved in-lieu fee fund). 6h. Comments: Page 10 of 14 E. Stormwater Management and Diffuse Flow Plan (required by DWQ) 1. Diffuse Flow Plan 1a. Does the project include or is it adjacent to protected riparian buffers identified X Yes ? No within one of the NC Riparian Buffer Protection Rules? 1 b. If yes, then is a diffuse flow plan included? If no, explain why. Comments: The proposed pump installation is a water dependent activity with diminimus increases in impervious surfaces; and therefore, a diffuse flow plan is not ? Yes X No required. A 6 foot wide temporary access entrance to Robinson Creek will impact the 25 foot Trout Water riparian buffer perpendicularly. The temporary access entrance will be seeded within 10 days of installation and will not be maintained. 2. Stormwater Management Plan 2a. What is the overall percent imperviousness of this project? diminimus % 2b. Does this project require a Stormwater Management Plan? ? Yes X No 2c. If this project DOES NOT require a Stormwater Management Plan, explain why: The proposed pump installation is a water dependent activity with diminimus increases in impervious surfaces; and therefore, a stormwater management plan is not required. 2d. If this project DOES require a Stormwater Management Plan, then provide a brief, narrative description of the plan: ? Certified Local Government 2e. Who will be responsible for the review of the Stormwater Management Plan? ? DWQ Stormwater Program ? DWQ 401 Unit 3. Certified Local Government Stormwater Review 3a. In which local government's jurisdiction is this project? Jackson County ? Phase II ? NSW 3b. Which of the following locally-implemented stormwater management programs ? USMP apply (check all that apply): ? Water Supply Watershed X Other: Jackson County Land Disturbance Application - Less than'/ acre 3c. Has the approved Stormwater Management Plan with proof of approval been ? Yes X No attached? 4. DWQ Stormwater Program Review ? Coastal counties ? HQW 4a. Which of the following state-implemented stormwater management programs apply ? ORW (check all that apply): X Session Law 2006-246 ? Other: 4b. Has the approved Stormwater Management Plan with proof of approval been attached? ? Yes X No 5. DWQ 401 Unit Stormwater Review 5a. Does the Stormwater Management Plan meet the appropriate requirements? X Yes ? No 5b. Have all of the 401 Unit submittal requirements been met? X Yes ? No Page 11 of 14 PCN Form - Version 1.3 December 10, 2008 Version F. Supplementary Information 1. Environmental Documentation (DWQ Requirement) 1a. Does the project involve an expenditure of public (federal/state/local) funds or the ? Yes ® No use of public (federal/state) land? 1b. If you answered "yes" to the above, does the project require preparation of an environmental document pursuant to the requirements of the National or State ? Yes ? No (North Carolina) Environmental Policy Act (NEPA/SEPA)? 1 c. If you answered "yes" to the above, has the document review been finalized by the State Clearing House? (If so, attach a copy of the NEPA or SEPA final approval letter.) ? Yes ? No Comments: 2, Violations (DWQ Requirement) 2a. Is the site in violation of DWQ Wetland Rules (15A NCAC 2H .0500), Isolated Wetland Rules (15A NCAC 2H .1300), DWQ Surface Water or Wetland Standards, ? Yes ® No or Riparian Buffer Rules (15A NCAC 2B .0200)? 2b. Is this an after-the-fact permit application? ? Yes ® No 2c. If you answered "yes" to one or both of the above questions, provide an explanation of the violation(s): 3. Cumulative Impacts (DWQ Requirement) 3a. Will this project (based on past and reasonably anticipated future impacts) result in ? Yes ® No additional development, which could impact nearby downstream water quality? 3b. If you answered "yes" to the above, submit a qualitative or quantitative cumulative impact analysis in accordance with the most recent DWQ policy. If you answered "no," provide a short narrative description. 4. Sewage Disposal (DWQ Requirement) 4a. Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of wastewater generated from the proposed project, or available capacity of the subject facility. The proposed project will not generate wastewater. Page 12 of 14 PCN Form - Version 1.3 December 10, 2008 Version 5. Endangered Species and Designated Critical Habitat (Corps Requirement) 5a. Will this project occur in or near an area with federally protected species or ® Yes ? No habitat? 5b. Have you checked with the USFWS concerning Endangered Species Act ® Yes No ? impacts? 5c. If yes, indicate the USFWS Field Office you have contacted. El Raleigh ? Asheville 5d. What data sources did you use to determine whether your site would impact Endangered Species or Designated Critical Habitat? The USFWS internet service, accessed May4, 2009, lists Carolina northern flying squirrel (Glaucomys sabrinus coloratus), Indiana bat (Myotis sodalis), Appalachian elktoe (Alasmidonta raveneliana), small whorled pogonia (Isotria medeoloides), swamp pink (Helonias bullata), and rock gnome lichen (Gymnoderma lineare) as occuring within Jackson County. As indicated in the Chinquapin Property Irrigation Supply Feasibility Analysis (EcoEngineedng, August 2008) an initial stream habitat assessment was conducted. No fish, mussel, clam, or snail, species were observed at the time of these investigations. In addition, no federally protected species were observed during field investigations. However, potential habitat exists within Robison Creek for.Appalachian elktoe. Therefore, Section 5a is marked yes. Although formal consultation with the U.S. Fish and Wildlife Service has not been pursued, based on the initial stream habitat assessment it is anticipated that the proposed project is not likely to adversely affect designated Appalachian elktoe habitat. 6. Essential Fish Habitat (Corps Requirement) 6a. Will this project occur in or near an area designated as essential fish habitat? ® Yes ? No 6b. What data sources did you use to determine whether your site would impact Essential Fish Habitat? The Clean Water Management Trust Fund internet service (accessed May 4, 2009; http://216.237.216.18/cwmtfweb/default.aspx) list WRC Troutwaters on the subject property. 7. Historic or Prehistoric Cultural Resources (Corps Requirement) 7a. Will this project occur in or near an area that the state, federal or tribal governments have designated as having historic or cultural preservation ? Yes ® No status (e.g., National Historic Trust designation or properties significant in North Carolina history and archaeology)? 7b. What data sources did you use to determine whether your site would impact historic or archeological resources? A review of the list of properties and districts in North Carolina entered in the National Register of Historic Places (http://www.hpo.ncdcr.gov/nrlist.htm) for Jackson County did not reveal any listing within the proposed project study area. It is believed the proposed project will not occur in or near an area that has been designated as having historic or cultural preservation status by the state, federal, or tribal governments. 8. Flood Zone Designation (Corps Requirement) 8a. Will this project occur in a FEMA-designated 100-year floodplain? ? Yes ® No 8b. If yes, explain how project meets FEMA requirements: 8c. What source(s) did you use to make the floodplain determination? NC FIRM Map Panel 7584 George Buchholz, REM, PWS January 5, 2010 Applicant/Agent's Printed Name A lic n A ent's nature Date Page 13 of 14 I-- I (Agent's signature is valid only if an authorization letter from the applicant is provided.) Page 14 of 14 SECTION 4 - WATER WITHDRAWAL RATES Month Day Target Area _ ........................................I# Gallons ipond Level +......_.. MaY.............._. .............19. Greens, Tee, Surrounds . ...... .. . ! 93,000 I. own 2" May _........._'........20 Fairways 111,7731Down 6.5" .............. ..aY .....................21i0.7" Rain i OlFuil Ma Y ...... _... 22 No Irrigation ......................................a ... _....... ..........._. 0 May . Ma _. „j 23INo Irrigation ... i . i 24 p ..... No Irrigation . ...._..... 0? ......................... May 25I No Irrigation I ....... ...... . 0 ay.... . ............ ...__...._......26,Handwatering.hotspots _ .... .................. ...._.. 17,753:Full ...... I May..... i . _.._.........27 Fairways .. ...... ....._ ! ...... .. ?..... .... 103,doolb- wn 9 May .... ! 11.1. ens, Tee, Surrounds I ... 110,OOO,Down 12.5" May 29?Fwys .. .. 111,000IDown 16.5" May May 30 Blow out on #9 tee 253 000 als g....._.j ...._. 31 No Irrigation i Down 25+? 0 0 ...... June... .. .......... ....... ....... ................ _....i........ .. I .No Irrigation .... ... ......_.._.............. .._... . _f. ; ..................... .. . . . . .. . . . .. . . ...._ OrI ......... .. ....... June 2 No Irrigation j . . . . . . .. . . .. . . .. _. _ .. 01 une 3 No irrigation 0 Down 17" June t 4[Hand watering hotspots i 5,000'Down 16" June S Greens, and hand watering 1 66,661 iDown 18" June ? 6 Hand watering hotspots 11,761 lb- 19.5" .... . June ..... ...... 711 'airways ... . . ;- 118,000I Down 24" June ... 8 Hand watering hotspots .........-..._.... 11,000i own28" une 9j Hand watering hotspots 33,Oddlb& n 3O"- --- ' June I _ 10,Greens, and hand watering , 31,327 'Down 35" June . 111)Greens, Tees, and Hoses ... . _ 63,012j?Down 37" Juna i 12iGreens i ...... ....67,413'Down 41" .... June 13fFairways, pond Dry"*"**......... 126,159jDown 47" une 14 !No Irrigation ....... ? ....... 0 ...... z une ? 15, No irrigation p June ............... 'Re ressurized. Turned on the v? ...?...__._........._..... _.... ..._.. ..._.._....................................... 1....... 0' Down 49' ........_........_._... June 17 No Irrigaton i 0 Down 37" June f......_18IGreens . ...... .. 67,0000own 34" June .. ................... ...... ._... ':. 19?Tees 30,000 Down 38.5" June .._...... ... . .. . 20 Hand watering hotspots.. I ?...... ,392 Down 36.5 " ... ..._ ............................ j June 21INo Irrigation , 01 June June 22 No Irrigation i 23 Hand 'w'aterin h t t I 0' " o s po s g ?. ........__... ...__-....p...._ ................i.. 5 832 Down 37 ........?............. June f 24,FairwaYS..........._.. i .......... ......20,316?Down 38.5"..... June . and .watering hotspots 54,33610own 39.5" June ' .261Hoses only FOND DRY l........ 10,390'Down 46.5" June 27iNo Irri gation i ,? O,pown 45 June ....... 28i No Irrigation i ..._. _.. .... .. OlDown 44" ....... ...- June ? rri 291No Igation 0 Down 43..._... " June ......... ........ 30 No. Irrigation .................. _..i.._........ 6 Down 42" JuIY ........ l J .......f ............_1.. No Irrigation 2 0 Down 40" y u Hand watering hotspots.. 12.728 ? Down 38.5" July 3 Fairways . 92,182 Down 43.5" July._ ..... 411-fand watering hotspots 11,2941Down 43" July ........... No Irrigation ....... O'Down 42" July ........ _... JuI ..... i........._61No Irrigation ......_......_................._ .....f .... N l i ti O'Down 41.5' ''... Y_ ... o rr ga ? ...:.......7i o!?....__._....... . 0 Down 39 Jul ........ .._. ' 8' No Irrigation, Turned on the well .. O Down 38" Y July !... July !..... ._....,9Greens ` 10!Greens and hand waterin ..... 1 ....... 9 17,310 Down 30" i........... 59 487 Down 33 July ..........._................ 11 Greens, Fairways, and Hand w 107180iDown 34" Jul' __.. .12! ,No Irrigation ........ . . OiDown 31" Jul ....... !.-.. July . ...... .......................... . 13'No Irriation ........ ?.._.........?.:.. ......... _ , ... 14: No Irrigation ........_...............! „ .... . 0 Down 29 _ ..... ............ ........... ......... ' 1 ............. NY ......... . 1 . .. ......... . I5Mo Irrigation 9 O Down 28 0 down 26" JulY Juiy 18 Hand watering hotsPots .. 17 Fairways, and Hand watering 17,000! wn 24" 117 922D 3 " July ? 18;Greens , own 0 44,9281Down291 SECTION 5 - PROJECT HISTORY U.S. ARMY CORPS OF ENGINEERS WILMINGTON DISTRICT Action ID. 2006-30849-350 County: Jackson GENERAL PERMIT (REGIONAL AND NATIONWIDE) VERIFICATION Property Owner / Authorized Agent: Trillium, Attn: Mr. Phil Ward Address: 15 Trillium Ctr Cashiers, NC 28717 Telephone No.: (828) 743-9951 Size and location of property (water body, road name/number, town, etc.): The project area is located in the Q111guapin Development near Cashiers, Jackson County, North Carolina. Coordinates for the site are 35 Q9.781 north and 83 03.560 west. Description of projects area and activity: The permittee Is authorized to impact jurisdictional waters of the U.S.- (unnamed tributaries to Packs Creek and Mill Creek) as follows: temporarily ImRact 390 linear feet of stream for 13 utility crossings and permanently Impact 12 linear feet of stream in order to address a perched culvert. Previous NWPs on the property authorized 60 linear feet of permanent impact to streams, 0.009 acre of permanent wetland impacts and temporary impacts associated with the construction of two bridges. Applicable Law: Section 404 (Clean Water Act, 33 USC 1344) ? Section 10 (Rivers and Harbors Act, 33 USC 403) Authorization: Regional General Permit Number: Nationwide Permit Number: 12, 29, and 33 Your work is authorized by the above referenced permit provided it is accomplished in strict accordance with the attached conditions, your submitted plans, and the following special conditions: 1. Excavation in the creek channels and soil disturbance within 25 feet of the top of the banks should not occur from October 15 to April 15 to protect trout spawning. 2. The use of rip-rap or any other engineered structures to stabilize stream beds should be avoided to the maximum extent possible. 3. All impacted stream beds shall be returned to preconstruction contours once the utilities are installed. 4. As detailed in the letter from Clearwater Environmental Consultants (CEC), Inc., dated March 8, 2007, CEC will monitor the installation of the temporary impacts and provide written reports, to include photos, to the USACE and the Division of Water Quality. These reports will detail stream stability, bank stabilization, effects of sedimentation, and detail any remedial action that may be necessary. These assessments will be conducted prior to installation, during construction, and post-construction. 5. As also detailed in the letter from CEC, the stream at the arch culvert located adjacent to lot 16 flows below the surface due to improper construction. The flow will be returned to the surface by installing a pond liner and removal of the excess rip rap. This work will be conducted within 30 days of the date of this letter. Any violation of the attached conditions or deviation from your submitted plans may subject the permittee to a stop work order, a restoration order and/or appropriate legal action. This verification will remain valid until the expiration date identified below unless the nationwide authorization is modified, suspended or revoked. If, prior to the expiration date identified below, the nationwide permit authorization is reissued and/or modified, this verification will remain valid until the expiration date identified below, provided it complies with all requirements of the modified nationwide permit. If the nationwide permit authorization expires or is suspended, revoked, or is modified, such that the activity would no longer comply with the terms and conditions of the nationwide permit, activities which have commenced (i.e., are under construction) or -2- are under contract to commence in reliance upon the nationwide permit, will remain authorized provided the activity is completed within twelve months of the date of the nationwide permit's expiration, modification or revocation, unless discretionary authority has been exercised on a case-by-case basis to modify, suspend or revoke the authorization. Activities subject to Section 404 (as indicated above) may also require an individual Section 401 Water Quality Certification. You should contact the NC Division of Water Quality (telephone (919) 733-1786) to determine Section 401 requirements. For activities occurring within the twenty coastal counties subject to regulation under the Coastal Area Management Act (CAMA), prior to beginning work you must contact the N.C. Division of Coastal Management. This Department of the Army verification does not relieve the permittee of the responsibility to obtain any other required Federal, State or local approvals/permits. If there are any questions regarding this verification, any of the conditions of the Permit, or the Corps of Engineers regulatory program, please contact Lori Beckwith at 828-271-7980. Corps Regulatory Official Lori Beckwith Date: July 9, 2007 Expiration Date of Verification: July 9, 2009 The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we continue to do so, please complete the attached customer Satisfaction Survey or visit hgp://www.saw.usace.army-miVWETLANDS/index.htmi to complete the survey online. Copy Furnished: Clearwater Environmental Consultants, Inc., Attn: Mr. Clement Riddle, 718 Oakland Street, Hendersonville, NC 28791