20191716 Ver 1_USACE Correspondence_20200124

Moore, Andrew W
From: Brown, David W CIV USARMY CESAW (US) <[e-mail]>
Sent: Friday, January 24, 2020 10:37 AM
To: [e-mail]
Cc: Moore, Andrew W; Leslie, Andrea J
Subject: [External] Comments and Request for Additional Information - Greystone Inn Shoreline
Wall (UNCLASSIFIED)
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CLASSIFICATION: UNCLASSIFIED
Action ID: SAW-2019-02431
T.E. Allen Engineering, PC
Rosman, NC 28772
Terry Allen,
The Corps has received (January 21) and reviewed your submitted response to the Corps request for additional
information dated December 23, 2020, for the proposed construction of a new 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 has the following comments
and is requesting additional information:
1. Your response failed to provide sufficient information and demonstrate the need for 499 linear feet (If) of shoreline
stabilization at this site. There appears to be sizable portions of shoreline in the project area which appear to be stable
and are currently not significantly eroding.
2. As stated previously, in order for the Corps to verify the use of Nationwide Permit (NWP) 13 for this project the
applicant must meet the criteria and conditions of the NWP. One of the criteria the activity must meet is no material is
placed in excess of the minimum needed for erosion protection.
3. You explained the need for 499 If of shoreline stabilization is based upon the chosen method/technique, specially the
construction of a precast segmental block wall. Other methods should be evaluated and considered as viable options to
remedy the areas of shoreline that are actively eroding which would meet the criteria and conditions of NWP 13. Have
you given consideration to other methods and/or combination of methods (sills, regarding slopes, use of vegetative
material, driven piles, stacked rock walls, etc.)?
4. If the primary purpose of the project is to stabilize eroding areas of shoreline at the site, then redesign the project
using a method that will meet the criteria and conditions of NWP 13. Once the Corps receives details of an acceptable
design of the shoreline stabilization activities we can continue to process your application under NWP 13.
5. If the overall propose of the project is not stabilization of eroding areas of shoreline, then withdraw the request for
utilization of NWP 13 for this project.

6. The project may be resubmitted for authorization under another NWP or as an individual permit. For example, if the
purpose of the project is for maintaining upland slopes and provide guest access to the lake, then it could potentially be
authorized under NWP 39. If resubmitting the project, you will need to state the purpose and need for the work and the
rational for the length of the proposed shoreline wall is the minimum needed to meet the purpose and need after taking
all the necessary avoidance and minimization measures/efforts.
Conductance of activities in areas outside of the Corps jurisdiction associated with the purpose and need of the
shoreline wall does not imply that this office will necessarily approve any future proposal to impact water of the U.S.
(WoUS). The conductance of clearing, grading, and construction activities will not affect the Corps review of future
proposed impacts to WoUS. The occurrence of clearing grading, and development activities at the property will not be
an adequate justification for authorization of future impacts to WoUS.
Please copy Andrew Moore with NC Department of Environment Quality, Division of Water Resources, and Andrea Leslie
with NC Wildlife Resources Commission on your response to this 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