20191716 Ver 1_More Info Received_20200827

Moore, Andrew W
From: [e-mail]
Sent: Thursday, August 27, 2020 4:29 PM
To: Moore, Andrew W
Cc: Yankura, Kaylie; [e-mail]1; Leslie, Andrea J
Subject: RE: [External] REVISED PCN for Greystone Inn Seawall, Lake Toxaway, Transylvania
Coubnty, NC
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[e-mail] A I
Hello Andrew:
Thank you for your timely reply.
1. The proposed pier/dock/ramp(s) will extend the entire 600 linear feet of the seawall. The seawall will also
function as the foundation for the shore -side portion of the pier/dock/ramp(s).
2. The seawall will provide the structural foundation for the pier/dock/ramp(s) that will run entire length for the
seawall (i.e., 600 LF). The shore -side of the pier/dock/ramp(s) will bear on the seawall, and the Lake -side
portion of the pier/dock/ramp(s) will be supported by wood pilings imbedded in the Lake bottom (no concrete
footers). Several applicable Code references are provided below.
Code Section 3607.1.2; "No structure shall be terminated without regard for end anchorage and
stabilization".
b. Code Section 3603.3(4); To provide end anchorage stabilization for the ramp, landing and dock; extend
bulkhead to resist lateral earth pressure and superimposed live loads for a minimum horizontal distance
of at least three (3) times height of Bulkhead.
c. ANSI A 117.1 and Code Section 1007.1.1. Pursuant to ANSI A 117.1, Section 1109.1.1, at least two
means of egress must be provided for swim areas. Per NC Building Code Section 1007.1.1, egress points
must be separated by a distance of one-half the diagonal of the area.
Please let me know if you have any questions or require any additional information.
Thank you.
Terry Allen, PE, MSE
T.E. ALLEN ENGINEERING, PC
P.O. Box 103
Rosman, NC 28772
828-877-4883 Office
828-553-3004 Mobile
From: Moore, Andrew W [mailto:[e-mail]]
Sent: Thursday, August 27, 2020 3:05 PM

To: [e-mail]
Cc: Yankura, Kaylie; [e-mail]; Leslie, Andrea J
Subject: RE: [External] REVISED PCN for Greystone Inn Seawall, Lake Toxaway, Transylvania Coubnty, NC
Terry,
Thank you for the response. I've read your email below several times in an attempt to understand the purpose of the
seawall. Correct me if I am wrong, but it appears from your first paragraph that the attendant features are the
recreational facilities, which I assume refers to the pier, docks, swim zone, and kayak launch area. Your last paragraph
indicates the attendant features (i.e. recreational facilities) are necessary for the use and maintenance of the structures.
I assume the structures are the existing building facilities on the property. If that's the case, it's not clear from your
submittal why the seawall is necessary to construct the recreational facilities. You have not demonstrated why a seawall
is necessary to construct a pier, dock, swim area, or kayak launch area. It seems as though you could swim, build a pier,
build a dock, and launch a kayak without a seawall.
Please provide the following information so the Division may complete the review of the project:
1. Do the proposed pier and/or docks extend along the entire 600 feet of proposed seawall? If not, where does
it/they terminate? [15A NCAC 02H .0506(b)(1)]
I understand that building code requires the 1,041 linear feet of lake access facilities, but you have not
explained why the seawall is necessary to provide/construct the lake access facilities. The construction details
provided with the submittal depict the seawall construction, but do not depict why the seawall is necessary for
the pier, docks, swim zone, and kayak launch area or the structural interaction between the seawall and these
recreational facilities. If the proposed pier and/or docks extend along the entire 600 feet of proposed seawall,
and if the seawall is necessary for structural support of proposed piers or docks, please provide a construction
detail that depicts, or otherwise demonstrate, that the seawall is necessary to construct the pier and docks. If
the pier or docks do not extend the entire 600 feet of proposed seawall, please also explain why the seawall is
needed in the shoreline segments that will not have a pier or dock. [15A NCAC 02H .0506(b)(1)]
The application will remain on hold until the requested information is received.
Thank you,
Andrew W. Moore, PG
Environmental Specialist II —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: Andrew.W.Moore(@ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: [e-mail] [mailto:[e-mail]]
Sent: Monday, August 24, 2020 3:55 PM
To: Moore, Andrew W <[e-mail]>

Cc: Yankura, Kaylie <[e-mail]>; [e-mail]; Leslie, Andrea J
<[e-mail]>
Subject: RE: [External] REVISED PCN for Greystone Inn Seawall, Lake Toxaway, Transylvania Coubnty, NC
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gov
Hello Andrew:
NWP 39 allows for fill material into non -tidal waters of the United States for the construction or expansion of
commercial and institutional building foundations and building pads and attendant features that are necessary for the
use and maintenance of the structures. Attendant features may include, but are not limited to, roads, parking lots,
garages, yards, utility lines, storm water management facilities, wastewater treatment facilities, and recreation
facilities....
The existing Greystone Inn commercial development has a maximum occupant load of 347 persons pursuant to Section
1004, of the 2018 NC Building Code.
The pier and dock requirement to support an occupant load of 347 persons is 1,041 linear feet pursuant to Section
3606.8 of the 2018 NC Building Code.
States another way; The Owner of the Greystone Inn wants to provide Lake access to all guests as an amenity to boost
business. The Building Code requires the Owner to provide over 1,041 linear feet of Lake access (i.e., access ramps,
docks, ADA access, etc.) to support a maximum occupant load of 347 persons. Since NWP 39 specifically allows for
"...attendant features that are necessary for the use and maintenance of the structures...", the seawall is justified and
necessary for the "use of the structure" because the NC Building requires 1,041 linear feet of Lake access facilities to
accommodate the maximum occupant load of the Greystone Inn.
Please call or email if you have any question or if you require any additional information.
Thank you.
Terry Allen, PE, MSE
T.E. ALLEN ENGINEERING, PC
P.O. Box 103
Rosman, NC 28772
828-877-4883 Office
828-553-3004 Mobile
From: Moore, Andrew W [mailto:[e-mail]]
Sent: Monday, August 24, 2020 3:11 PM
To: tealleneng comporium.net
Cc: Yankura, Kaylie; [e-mail]; Leslie, Andrea J
Subject: RE: [External] REVISED PCN for Greystone Inn Seawall, Lake Toxaway, Transylvania Coubnty, NC
Terry,
On December 13, 2019, the Division of Water Resources received your application requesting a 401 Water Quality
Certification for the subject project. Additional information was received July 29, 2020, in support of the application. The

Division has determined that your application is incomplete and cannot be processed. The application is on hold until all
of the following information is received.
Please clearly explain the purpose of the seawall. There are a number of references to NC Building Code.
However, it's not clear how those references are applicable to the overall project purpose. If the purpose of the
wall varies across the proposed 600 feet, please itemize the various wall purposes and include the proposed
lengths for each section. The Division cannot certify the project has avoided and minimized impacts until the
project purpose has been clearly identified. [15A NCAC 02H .0506(b)(1)]
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested information for the
proper consideration of the application. If all of the requested information is not received, the Division will be unable to
approve the application and it will be denied as incomplete.
Feel free to contact me if you have any questions.
Andrew W. Moore, PG
Environmental Specialist II —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: And rew.W.Moore(�Ocdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: [e-mail][mailto:[e-mail]]
Sent: Wednesday, July 29, 2020 2:18 PM
To: Moore, Andrew W <[e-mail]>; [e-mail]1; Leslie, Andrea J
<[e-mail]>
Cc: Yankura, Kaylie <[e-mail]>
Subject: [External] REVISED PCN for Greystone Inn Seawall, Lake Toxaway, Transylvania Coubnty, NC
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Hello All:
Please find the attached "revised" PCN Form along with supporting drawings and documentation. This "revised" PCN
changes from NWP 13 to NWP 39.
The attached drawings should be printed on standard 8-1/2"x11" paper.
Please call or email if you have any questions.

Thank you.
Terry Allen, PE, MSE
T.E. ALLEN ENGINEERING, PC
P.O. Box 103
Rosman, NC 28772
828-877-4883 Office
828-553-3004 Mobile
From: Moore, Andrew W[mailto:andrew.w.moore(a)ncdenr.gov]
Sent: Wednesday, July 15, 2020 10:39 AM
To: tealleneng comporium.net
Cc: Leslie, Andrea J; Brown, David W CIV USARMY CESAW (US)
Subject: RE: [External] Request for Additional Information - Greystone Inn Shoreline Wall (UNCLASSIFIED)
Terry,
The Division has not received a response to the request below. If a response is not received in the near future, the
Division will return the application, which will necessitate re -submittal for project approval.
Please let me know if the applicant is no longer requesting a 401 Water Quality Certification for the project.
Andrew W. Moore, PG
Environmental Specialist II —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4684 office
email: And rew.W.Moore(c�ncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Moore, Andrew W
Sent: Monday, December 23, 2019 1:25 PM
To: [e-mail]
Cc: Leslie, Andrea J <[e-mail]>; Brown, David W CIV USARMY CESAW (US)
<[e-mail]>
Subject: RE: [External] Request for Additional Information - Greystone Inn Shoreline Wall (UNCLASSIFIED)
Terry,

On December 13, 2019, the Division of Water Resources received your application requesting a 401 Water Quality
Certification for the subject project. The Division has determined that your application is incomplete and cannot be
processed. The application is on hold until all of the following information is received:
The Division cannot process your application until the Corps verifies the appropriate permit type for the
proposed activity. Please copy the Division on your response to the Corps' Request for Additional Information
email below. [15A NCAC 02H .0501(b)(2)]
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested information for the
proper consideration of the application. If all of the requested information is not received, the Division will be unable to
approve the application and it will be denied as incomplete.
Feel free to contact me if you have any questions.
Andrew W. Moore, PG
Environmental Specialist —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ— Division of Water Resources
828 296 4684 office
email: [e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
-----Original Message -----
From: Brown, David W CIV USARMY CESAW (US)[mailto:[e-mail]]
Sent: Monday, December 23, 2019 11:26 AM
To: [e-mail]
Cc: [e-mail]; [e-mail]; Moore, Andrew W
<[e-mail]>; Leslie, Andrea J <[e-mail]>
Subject: [External] Request for Additional Information - Greystone Inn Shoreline Wall (UNCLASSIFIED)
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to repo [e-mail]<mailto:[e-mail]>
CLASSIFICATION: UNCLASSIFIED
Action ID: SAW-2019-02431
T.E. Allen Engineering, PC
Rosman, NC 28772
Terry Allen,

The Corps has received (December 12) and reviewed your submitted Pre -Construction Notification (PCN) application and
supporting documents for the proposed construction of new shoreline wall and replacement of sections of existing
shoreline wall at the Greystone Inn property. The project site is located on a 2.29 acre tract of land (PIN 8512-89-6791-
000) at 220 Greystone Lane in Lake Toxaway, Transylvania County, NC. Coordinates are 35.14119 N, 82.95243 W. The
Corps is requesting the following additional information in order for us to consider the application to be complete:
1. In order for the Corps to verify the use of Nationwide Permit 13, Bank Stabilization, for this project the applicant must
meet the criteria and conditions of the nationwide permit (NWP). One of the criteria the activity must meet is no
material is placed in excess of the minimum needed to erosion protection. Explain why 499 linear feet of shoreline
stabilization is being proposed when there are sizable portions of shoreline in the project area which appear to be stable
and are currently not significantly eroding.
2. Provide the length of existing shoreline wall in the project area that is to be replaced.
3. The proposed project is within the FEMA 100-year floodway (Zone AE, special flood hazard area). Per the general
conditions of the NWP, the activity must comply with applicable FEMA-approved state or local floodplain management
requirements. Provide an explanation of how the project meets these requirements.
At this time, the request to utilize NWP 13 for authorization of impacts to WoUS is on hold until the above additional
information has been received. Once the Corps receives the information noted above, then we will be able to continue
to process your request. If you have any questions please contact me.
Sincerely,
David Brown, PG
Regulatory Specialist/Geologist
USACE Wilmington District -Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
828-271-7980, ext. 4232
[e-mail]
CLASSIFICATION: UNCLASSIFIED
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