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HomeMy WebLinkAbout20200987 Ver 1_Public Comments_20200914Brown, David W CIV USARMY CESAW (USA) From: Pace Wilber - NOAA Federal <pace.wiiber@noaa.gov> Sent: Wednesday, July 8, 2020 8:49 AM To: Brown, David W CIV USARMY CESAW (USA) Cc: Fritz Rohde - NOAA Federal; Twyla Cheatwood - NOAA Federal Subject: [Non-DoD Source] NMFs no staff letter for NCWR Lake Adger SAW-2015-00788 Attachments: NCWRC-LakeAdger SAW-2015-00788_NoStaffingNoEFHPresent.pdf (UNITED STATES DEPARTMENT OF COMMERCE vt#,*T 8"-++ National Oceanic and Atmospheric Administration ;r + NATIONAL MARINE FISHERIES SERVICE Southeast Regional Office 263 131, Avenue South °•�Tcne��° St. Petersburg, Florida 33701-5505 https://www.fisheries.noaa.gov/reclion/southeast (Sent via Electronic Mail) Colonel Robert J. Clark, Commander USACE Wilmington District 69 Darlington Avenue Wilmington, North Carolina 28403-1398 Dear Colonel Clark: July 8, 2020 NOAA's National Marine Fisheries Service (NMFS) reviewed the project described in the public notice listed below. Based on the information in the public notice, the proposed project would NOT occur in the vicinity of essential fish habitat (EFH) designated by the South Atlantic Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS. Present staffing levels preclude further analysis of the proposed work and no further action is planned. This position is neither supportive of nor in opposition to authorization of the proposed work. Notice No. Applicant(s) Notice Date SAW-2015-00788 NC Wildlife Resources July 7, 2020 Commission; Lake Adger Please note these comments do not satisfy consultation responsibilities under section 7 of the Endangered Species Act of 1973, as amended. If an activity "may effect" listed species or critical habitat under the purview of the NMFS, please initiate consultation with the Protected Resources Division at the letterhead address. /for Sincerely, ly signed byWILBERTHOMASY WILBER31-OMASPAYSON.136582 AYSON.1365820186 0186 Date: 2020.07.08 08:4S:S6 -000' Virginia M. Fay Assistant Regional Administrator Habitat Conservation Division �`�1TM)SP/�EgC Q W� }�2 4 �MErn OF��� Brown, David W CIV USARMY CESAW (USA) From: Homewood, Sue <sue.homewood@ncdenr.gov> Sent: Thursday, August 6, 2020 3:40 PM To: Brown, David W CIV USARMY CESAW (USA) Cc: Leslie, Andrea J; Hamstead, Byron A; Robert Cork, Yankura, Kaylie Subject: [Non-DoD Source] Lake Adger Maintenance Dredging Comments Attachments: 20200987 Ver 1-Comments to USACE_20200803.pdf Please see attached. Hard copies will not be sent unless specifically requested. Sue Homewood Division of Water Resources, Winston Salem Regional Office Department of Environmental Quality 336 776 9693 office 336 813 1863 mobile Sue.Homewood@ncdenr.gov 450 W. Hanes Mill Rd, Suite 300 Winston Salem NC 27105 )ocuSign Envelope ID: AD52759E-03A9-40A5-B5B04EBBC29A50E7 ROY COOPER Governor MICHAEL S. REGAN seartary S. DANIEL SMITH DUector NORTH CAROLINA Environmental Quality August 3, 2020 Corps Action ID# SAW-2015-00788 DWR# 20200987 Polk County Mr. David Brown U.S. Army Corps of Engineers Asheville Regulatory Field Office 151 Patton Ave, Room 208 Asheville, North Carolina 28801-5006 Subject Project: Lake Adger Channel Maintenance Dredging Dear Mr. Brown, On behalf of the NC Division of Water Resources, we respectfully request that you consider the fallowing comments within your review of the 404 Individual Permit request for the above referenced property: The application notes that a wetland monitoring plan will be developed with input from the resource agencies. We request that a detailed and complete monitoring plan for wetland impact areas be finalized prior to issuance of approvals. 2. The Division acknowledges that the applicant's intent is to enhance and/or create wetlands as a result of this project, however the Division recommends that this should be monitored and that a detailed course of action should be developed should the project inadvertently cause a loss of wetlands. We recommend that the monitoring plan include a requirement for a new jurisdictional determination (in areas of dredge spoil fill) and that NCWAM evaluations be conducted to ensure that the wetlands to be filled by dredge material do not lose jurisdiction or incur a degradation of function. We recommend that any approvals include a condition that should either loss of jurisdiction or loss of function occur, the Permittee would be required to provide a mitigation plan to compensate for the loss. The creation of new wetland areas within the lake may be proposed as "permittee responsible mitigation" provided they satisfy mitigation site criteria at the time of proposal. North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617 919.707.9000 locuSign Envelope ID: AD52759E-03A9110A5-B5B0-4EBBC29A50E7 Corps Action ID# SAW-2015-00788 DWR# 20200987 Page 2 of 2 3. The Division recommends that the applicant provide a detailed phasing and/or construction sequencing plan proposed for this project. For instance, will dredging activities be confined within certain portions of the lake until completion/before progressing to the next work area? How does the construction sequencing tie into the containment system design and turbidity monitoring proposals? 4. The Division recommends that a more detailed and robust turbidity monitoring plan is necessary and will coordinate with the applicant during 401 application review. The applicant mentions future routine dredging activities to be covered by this approval. The Division recommends that prior to commencement of any future dredging or disposal activities the areas to be used for disposal should be re-evaluated by the regulatory agencies and may require updated jurisdictional determinations and/or NCWAM evaluations, and that updated monitoring plans to be developed for each future area which is proposed to impact wetlands, and should be conditioned to require mitigation of any future loss of jurisdiction or function as noted above. Thank you for your considering the Division's comments during your review of this Individual Permit. Please note that the Division received the 401 application on July 31, 2020 and has not conducted a complete technical review at this time. Upon detailed review, additional information may be necessary prior to issuance of a 401 individual certification. If you have any questions, please contact Sue Homewood at 336-776-9693 or sue.homewood@ncdenr.gov. Sincerely, DoeuSigned by: 949D91 BA53EF4E0... Paul Wojoski, Supervisor 401 & Buffer Permitting Unit cc: Robert Cork, Anchor QEA of North Carolina LLC (via email) Andrea Leslie, NCWRC (via email) Byron Hamstead, USFWS (via email) DWR ARO DWR —Wetlands and Buffer Permitting Branch Brown, David W CIV USARMY CESAW (USA) From: DCR - Environmental -Review <Environmental.Review@ncdcr.gov> Sent: Monday, August 3, 2020 2:36 PM To: Wallace, Nancy L CIV USARMY CESAW (US); Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] Re: [External] US Army Corps of Engineers Wilmington District Public Notice (UNCLASSIFIED) Attachments: GS 17-2950.pdf Our response is attached. Thank you. Devon L. Borgardt Environmental Review Assistant North Carolina Historic Preservation Office 109 E Jones St MSC 4619 Raleigh, NC 27699 919 814 6586 office Devon.bor¢ardta,ncdcr.gov 0 #StayStrongNC Learn more @ nc.gov/covidl9 And don't forget your Ws! Wear. Wait. Wash. WEAR a face covering. WAIT 6 feet apart from other people. WASH your hands often. Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Facebook Twitter Instagram YouTube From: Wallace, Nancy L CIV USARMY CESAW (US) <Nancy.Wallace@usace.army.mil> Sent: Monday, July 6, 2020 7:46 AM Subject: [External] US Army Corps of Engineers Wilmington District Public Notice (UNCLASSIFIED) CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov> CLASSIFICATION: UNCLASSIFIED As you renuested, you are hereby notified that Wilmington District, United States Army Corps of Engineers has issued a Public Notice. The text of this document can be found on the Public Notices portion of the Regulatory Division Home Page. Each Public Notice is available in ADOBE ACROBAT (.pdf) format for viewing, printing or download at Blockedhttps://urldefense.com/v3/ http://www.saw.usace.army.mil/Missions/Regulatory-Permit-Program/Public- Notices/;!!HYmSToo!PUn9iBNStoiRnYpXKOcZVRYC1SFpzYlaaDtnmuGwZEPIAcLgDz74UCvyOcQxNloUlBdugUoy3n8$ As with anything you download from the internet, be sure to check for viruses prior to opening. The current notice involves: Corps Action ID#: SAW-2015-00788 (Lake Adger Dredging) Issue Date: July 6, 2020 Applicant: Mr. Jeff Ferguson of the North Carolina Wildlife Resources Commission Expiration Date: 5:00 p.m., August 7, 2020 Point of Contact: Mr. David Brown, 828-271-7980 Ext 4232 Project Description: The Wilmington District, Corps of Engineers (Corps or USACE) received an application from Mr. Jeff Ferguson of the North Carolina Wildlife Resources Commission (NCWRC or WRC) seeking Department of the Army (DA) authorization for 7.5 acres (ac) of permanent impacts to open waters (dredging and conversion to wetlands); 9.5-ac of temporary impacts to open waters (dredging); 1.1-ac of permanent impacts to wetlands (fill); and 3.0-ac of temporary impacts to wetlands (dredging), associated with dredging of the recreational navigation channel between the Lake Adger public boat access area and the lake's main channel adjacent to the Lake Adger Marina in Mill Spring, Polk County, North Carolina. Subscribe/Unsubscribe: This email was sent out as a result of subscribing to the Wilmington District regulatory program public notices. Please reply to this email with the subject or message "unsubscribe" to remove your address from future mailings. CLASSIFICATION: UNCLASSIFIED North Carolina Department of Natural and Cultural Resources State Historic Preservation Office Ramona M. Banos, Administrator Governor Roy Cooper Secretary Susi H. Hamilton August 3, 2020 Mr. David Brown USACE Wilmington District Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, North Carolina, 28801 Re: Lake Adger Dredging Project, Polk County, ER GS 17-2950 ZD Dear Mr. David Brown: Thank you for your email of July 6, 2020 concerning the above project. Office ofArchives and History Deputy Secretary Kevin Cherry david.w.brown@usace.army.mil We have conducted a review of the project and are aware of no historic resources which would be affected by the project. Therefore, we have no comment on the project as proposed. The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR Part 800. Thank you for your cooperation and consideration. If you have questions concerning the above comment, contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or environmental.review@ncdcr.gov. In all future communication concerning this project, please cite the above referenced tracking number. Sincerely, r} 6fRamona Bartos, Deputy State Historic Preservation Officer Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617Mail Service Center, Raleigh NC 17699-4617 Telephone/Pax (919) 807-6I70/807-6199 Brown, David W CIV USARMY CESAW (USA) From: Elizabeth Toombs <elizabeth-toombs@cherokee.org> Sent: Tuesday, August 4, 2020 2:14 PM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] SAW-2015-00788 Attachments: 080420 USACE COR SAW-2015-00788 Lake Adger.pdf Mr. Brown: Attached is Cherokee Nation's response to the proposed undertaking. Please let me know if there are any questions or concerns. Wado, Elizabeth Toombs, Tribal Historic Preservation Officer Cherokee Nation Tribal Historic Preservation Office PO Box 948 Tahlequah, OK 74465-0948 918.453.5389 Office of the Chief CWY.6 D$P Chuck Hoskin Jr. CHEROKEE NATION® Principal Chief Bryan Warner P.O. Box 948 • Tahlequah, OK 74463-0948 Deputy Principal Chief 918-453-S111X1 • www chemkce.twg August 4, 2020 David Brown United States Army Corps of Engineers Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, NC 28801-5006 Re: SAW-2015-00788, Proposed Dredging of Lake Adger Mr. David Brown: The Cherokee Nation (Nation) is in receipt of your correspondence about SAW-2015-00788, and appreciates the opportunity to provide comment upon this project. Please allow this letter to serve as the Nation's interest in acting as a consulting party to this proposed project. The Nation maintains databases and records of cultural, historic, and pre -historic resources in this area. Our Historic Preservation Office reviewed this project, cross referenced the project's legal description against our information, and found no instances where this project intersects or adjoins such resources. Thus, the Nation does not foresee this project imparting impacts to Cherokee cultural resources at this time. However, the Nation requests that the United States Army Corps of Engineers (USACE) halt all project activities immediately and re -contact our Offices for further consultation if items of cultural significance are discovered during the course of this project. Additionally, the Nation requests that USACE conduct appropriate inquiries with other pertinent Tribal and Historic Preservation Offices regarding historic and prehistoric resources not included in the Nation's databases or records. If you require additional information or have any questions, please contact me at your convenience. Thank you for your time and attention to this matter. Wado, Elizabeth Toombs, Tribal Historic Preservation Officer Cherokee Nation Tribal Historic Preservation Office elizabeth-tombs@cherokee.org 918.453.5389 Brown, David W CIV USARMY CESAW (USA) From: Leslie, Andrea J <andrea.leslie@ncwildlife.org> Sent: Thursday, August 13, 2020 2:56 PM To: Brown, David W CIV USARMY CESAW (USA) Cc: Homewood, Sue; Moore, Andrew W; Byron Hamstead (byron_hamstead@fws.gov); Robert Cork; Ferguson, Jeff C; Loftis, C. Scott Subject: [Non-DoD Source] Lake Adger Dredging project - NCWRC comments Attachments: LAdgerDredging_Polk_WRCComments.pdf Hi David, Attached are NCWRC's comments on the Lake Adger dredging project. Andrea Leslie Mountain Habitat Conservation Coordinator NC Wildlife Resources Commission 645 Fish Hatchery Rd., Building B Marion, NC 28752 828-803-6054 (office) 828-400-4223(cell) Blockedwww.ncwildlife.org Get NC Wildlife Update delivered to your inbox from the N.C. Wildlife Resources Commission. Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties. ® North Carolina Wildlife Resources Commission Cameron .Ingram, Executive Director August 13, 2020 Mr. David Brown U.S. Army Corps of Engineers, Regulatory Branch 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 SUBJECT: Lake Adger Navigation Channel Maintenance Dredging Lake Adger Wetlands, Polk County SAW-2015-00788 Dear Mr. Brown: Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the individual 404 permit application modification for the Lake Adger Navigation Channel Maintenance Dredging project, which would temporarily impact 3 acres and permanently impact 1.1 acres of wetland, as well as temporarily impact up to 14 acres and permanently impact 3 acres of open water, in Lake Adger in Polk County. NCWRC is the applicant for the permit, and staff are familiar with the site and have attended multiple site visits. Our comments on this application are offered for your consideration under provisions of the Clean Water Act of 1977 (33 U.S.C. 466 et. seq.) and Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d). Project activities should not impact wild trout reproduction, and a moratorium is not needed. The permit is associated with the dredging of a navigation channel from the boat dock to the lake. 6,800 yd3 of sediment would be hydraulically dredged in 2020-2021 from the navigation channel, 3,800 yd3 of which are required to make the channel navigable. An additional 3,000 yd3 of sediment will be dredged at the navigation channel location, and this additional amount is meant to compensate for sediment lost to the Big Hungry River during the removal of the lower Big Hungry River dam in 2015. The dredged sediment would be piped 1,500 ft to be placed in shallow in -lake placement areas Al and A2. The sediment would be allowed to drain in place and contoured to create new or enhance existing wetlands, as well as create upland habitat. The areas would be planted with native herbaceous and woody vegetation, using an adjacent wetland/upland complex as a reference for the plant list. Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 Lake Adger Dredging Page 2 August 13, 2020 L Adger & wetlands, Polk Co Total disturbance for the project would be 22.3 acres, including 4.5 acres for the navigation channel and 3.9 acres for sediment placement. The individual permit describes four areas for sediment placement (A1, A2, B1, and C1, totaling 3.9 acres) that would allow for sediment placement for the 6,800 yd3 and for future dredging activities. 1.1 acres of this sediment placement area is jurisdictional wetland. The sediment placement areas would be surrounded by two rows of biodegradable and/or temporary containment materials (e.g., hay bales) as well as a silt curtain beyond these rows; these measures are meant to hold sediment in place (especially the first row of material) and control turbidity. Turbidity would be monitored upstream and downstream of the activities, with turbidity sampled once each day at the upstream reference and twice each day downstream for the first week, with the goal of not increasing turbidity by more than 50 NTU from the upstream location. If the turbidity goal is met during the first week, monitoring frequency would be cut back to once per day. The application states that a review and possible change in activity will be taken only if turbidity is 100 NTU or more above the upstream reference. It is unknown if any action would be taken if turbidity increases 50-100 NTU from the reference. We offer the following comments and recommendations on this project: • The turbidity monitoring and contingency plan should be revised with the input of NC Division of Water Resources (NCDWR). • The vegetation monitoring plan should be developed with the input of NCDWR, US Army Corps of Engineers, and NCWRC. • We recommend adding Needle Spikerush and Silky Willow to the wetland plant list and Persimmon and Black Gum to the upland plant list. • Herbivory control fencing should consist of fabric that will not trap animals. NCWRC biologists can provide recommendations at to the type of fencing that is appropriate. • Although the text notes that 3.9 acres of area will be used for sediment placement, Sheet C5 notes that 1.1 acres of wetland and 3.0 acres of open water will be impacted by fill, which totals 4.1 acres. These differences should be rectified. Thank you for the opportunity to review and comment on this project. Please contact me at (828) 400-4223 if you have any questions about these comments. Sincerely, Andrea Leslie Mountain Region Coordinator, Habitat Conservation Program ec: Robert Cork, Anchor QEA Kaylie Yankura & Sue Homewood, NC Division of Water Resources Byron Hamstead, US Fish and Wildlife Service Jeff Ferguson & Scott Loftis, NCWRC Brown, David W CIV USARMY CESAW (USA) From: laura.e.baird@everyactioncustom.com on behalf of Laura Baird <laura.e.baird@everyactioncustom.com> Sent: Friday, August 21, 2020 9:57 AM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] Lake Adger Dredging Project: Request for Water Quality Protections, Better Public Access & More Dear Reg. Specialist David Brown, I am pleased to see that NC Wildlife Resources Commission (NCWRC) has submitted a permit application to dredge the public access channel at Lake Adger as it is obligated to do under the lake management agreement, and to use the dredge spoils to construct engineered wetlands on the existing sediment delta. I support this important project to protect public access to Lake Adger, since the channel has become nearly impassible to boat traffic due to sedimentation. I have some suggestions to make this project as successful as possible and to protect water quality during and after the project: Stakeholder Consultation - I request that NCWRC convene a stakeholder group consisting of parties to the lake management agreement (Polk County, Lake Adger Property Owners Association, Northbrook Energy), MountainTrue's Green Riverkeeper, and other interested parties like members of the fishing and boating community to receive feedback and input on the details of the project. These project details would include timing, potential impacts to access and water quality, lake level fluctuations, and other concerns of public interest. Sediment Management - I appreciate the detailed turbidity monitoring protocols and support all efforts to control sediment impacts during and after the project. I suggest adding silt curtains around the dredging area, not just around the wetland construction area. Wetland Construction - I support the strongest and most protective methods to contain and dewater material used to construct wetlands. While hay bales may be cost effective to contain spoil material to form engineered wetlands, options like coir fiber biologs, geotubes, and others should be explored to ensure that the best available technology is incorporated into the project. NCWRC should specifically consider how high water events may impact constructed wetlands and how these impacts can be mitigated. Wetland Planting - I request that Water Willow be removed from the wetland planting list. NCWRC is currently studying whether Water Willow is appropriate for introduction to Lake Adger, as it does not currently grow there. Following the precautionary principle, this plant should not be introduced as part of this project. Rather, NCWRC should continue its study and consult stakeholders on the potential future introduction of Water Willow. Habitat Considerations - Be mindful of aquatic and wetland wildlife habitat, especially fish spawning beds that can be affected by fluctuations in lake levels. Expanded Public Access and Educational Opportunities - NCWRC should consider opportunities to expand and improve public access and education in the project area, such as boardwalks, docks, fishing piers, and educational signage explaining the history of the lake and the ecological significance of the Green River and surrounding area. Public Communication - NCWRC should clearly communicate project details and timelines with the public as plans are finalized. Thank you for your consideration of these comments, and for the US Army Corps of Engineers' oversight and guidance of this important project to protect public access to Lake Adger. Sincerely, Laura Baird 92 Mill Shoals Rd Mill Spring, NC 28756-4767 laura.e.baird@gmail.com INI,l l S p,r tvi�, , J c �•K 'TiicSjy�'`{iF!yR4' •+, .. r OC � �(P .. ....._.._.. ._...._ .. 12e : 56vj= ao'5-4)o`l nd 05 1.5 I o,� �e., 'Y�-� a of a '6- %o l - 500 � I ill IIII)III Idil'Ij111'.'��t:��ii��ili!'�J�l"!'���l�I��ia��nlii3 r Mr. David Brown USACE Wilmington District Asheville Regulatory Field Office 151 Patton Ave, Room 208 Asheville, NC 28801-5006 —. r, AUG 1 0 2p fp BY: ..._............. Monika Mayr 78 Cove Lane Mill Spring, NC 28756 Re: Public Comment Concerning Lake Adger Marina Dredging Project, ID # SAW-2015-00788 Dear Mr. Brown: Thank you for the opportunity to comment on this important project that improves public access to Lake Adger. I appreciate the effort to gather and consider comments of interested parties, especially those that live on Lake Adger like I do. I agree with many of the comments presented by MountainTrue and am including them below with my additional comments. Stakeholder Consultation - NCWRC should convene a stakeholder group consisting of parties to the lake management agreement (Polk County, Lake Adger Property Owners Association, Northbrook Energy), MountainTrue's Green Riverkeeper, and other interested parties like members of the fishing and boating community to receive project details and provide pertinent feedback and input including project timing, potential impacts to water quality and lake habitat, lake level fluctuations, and other concerns of public interest. Sediment Management — I appreciate the detailed turbidity monitoring protocols and support all efforts to control sediment impacts during and after the project. I suggest adding silt curtains around the dredging area, not just around the wetland construction area and reducing the impact trigger from 100 NTU's to 75 NTU's. Additionally, if the trigger is activated, project specifications should clearly call for ceasing all operations until corrective actions are enacted and the turbidity levels return to 50 NTU's or below. Corrective operations must be initiated and not simply reviewed or monitored more frequently. Wetland Construction - I support methods to contain and dewater material used to construct wetlands that do not introduce living non-native material or non -biodegradable material. While hay bales may be cost effective to contain spoil material to form engineered wetlands, options like coir fiber biologs, geotubes, and others should be explored to ensure that the least environmentally damaging technology is incorporated into the project. NCWRC should specifically consider how high water events may impact constructed wetlands and how impacts can be mitigated. Wetland Planting - Water Willow must be removed from the wetland planting list. It is a nuisance plant that cannot be planted in a way that prevents its migration. Only material native to Lake Adger or the nearby area should be used in this project. Habitat Considerations - Be mindful of aquatic and wetland wildlife habitat, especially fish spawning beds that can be affected by fluctuations in lake levels and do not lower lake levels when fish are spawning on their beds. Expanded Public Access Opportunities - NCWRC should consider opportunities to expand and improve public access and education in the project area, such as boardwalks, docks, fishing piers, and educational signage explaining the history of the lake and the ecological significance of the Green River and surrounding area. Public Communication - NCWRC should clearly communicate project details and timelines with the public, especially Lake Adger residents, as plans are finalized. Again, thank you for the opportunity to comment on this important project. Sincerely, Monika Mayr Lake Adger Resident ,tdN!�"M1 may:. Y/e[4:✓vR:i FOREVER in GET ;:Au" 0 061/ F r� h�S D-�j9!l�IPPl�S � � r r 2SE,W6"s °:'i4=tr' ry\ CL -t4 C-� 0-�� /; (-,a- - , el In /4 -,�"""'Ol "e,;;17 "10001��� oP�kz' Abe Vd O'j- arnU', uJR'o/e' /xc .gym, Ra✓z �� "I na✓,'.Q ,�^' '�% ✓✓��'�` � , Jon^,° is '%�G � / �✓'. �'" 'j a,7,d� 6110-A-1 1 Brown, David W CIV USARMY CESAW (USA) From: Gray Jernigan <gray@mountaintrue.org> Sent: Thursday, August 6, 2020 3:18 PM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] SAW-2015-00788 - Lake Adger Dredging Public Comment Attachments: USACE Lake Adger Dredging Comments.pdf Mr. Brown, Please find the attached comments submitted on behalf of MountainTrue in regard to the permit application to dredge the public access channel at Lake Adger. We're glad to see this project moving forward, and thank you and your staff for all you do to serve the citizens of WNC. Sincerely, Gray Jernigan Southern Regional Director & Green Riverkeeper MountainTrue 121 Third Avenue West, Suite 1 Hendersonville, NC 28792 (828) 692-0385 ext.1004 Blockedwww.mountaintrue.ore Follow us on Facebook & Twitter Waterkeeper Alliance Member MountainTrue is committed to keeping our mountain region a beautiful place to live, work and play. Our members protect our forests, clean up our rivers, plan vibrant and livable communities, and advocate for a sound and sustainable future for all residents of WNC. BUILD A BETTER TOMORROW FOR WESTERN NORTH CAROLINA. BE MOUNTAINTRUE. JOIN TODAY: mountaintrue.org/loin mauntaintrue. Protecting the Places We Share. August 6, 2020 Mr. David Brown USACE Wilmington District Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, North Carolina, 28801-5006 RE: SAW-2015-00788 - Lake Adger Dredging Public Comment Dear Mr. Brown, We are pleased to see that NC Wildlife Resources Commission (NCWRC) has submitted a permit application to dredge the public access channel at Lake Adger as it is obligated to do under the lake management agreement and to use the dredge spoils to construct engineered wetlands on the existing sediment delta that has formed over the years since the Green River was dammed in 1925 creating the lake. We support this important project to protect public access to Lake Adger since the channel has become nearly impassible to boat traffic due to sedimentation. We have some suggestions to make this project as successful as possible and to protect water quality during and after the project: • Stakeholder Consultation - We request that NCWRC convene a stakeholder group consisting of parties to the lake management agreement (Polk County, Lake Adger Property Owners Association, Northbrook Energy), MountainTrue's Green Riverkeeper, and other interested parties like members of the fishing and boating community to receive feedback and input on the details of the project including timing, potential impacts to access and water quality, lake level fluctuations, and other concerns of public interest. • Sediment Management - We appreciate the detailed turbidity monitoring protocols and support all efforts to control sediment impacts during and after the project. We suggest adding silt curtains around the dredging area, not just around the wetland construction area. • Wetland Construction - We support the most protective and strongest methods to contain and dewater material used to construct wetlands. While hay bales may be cost effective to contain spoil material to form engineered wetlands, options like coir fiber biologs, geotubes, and others should be explored to ensure that the best available technology is incorporated into the project. NCWRC should specifically consider how high water events may impact constructed wetlands and how impacts can be mitigated. 121 Third Avenue West, Suite 1, Hendersonville, NC 28792 • Wetland Planting - We would request that Water Willow be removed from the wetland planting list. NCWRC is currently studying whether Water Willow is appropriate for introduction to Lake Adger, as it does not currently grow there. Following the precautionary principle, this plant should not be introduced as part of this project. Rather, NCWRC should continue its study and consult stakeholders on the potential future introduction of Water Willow. • Habitat Considerations - Be mindful of aquatic and wetland wildlife habitat, especially fish spawning beds that can be affected by fluctuations in lake levels. • Expanded Public Access and Educational Opportunities - NCWRC should consider opportunities to expand and improve public access and education in the project area, such as boardwalks, docks, fishing piers, and educational signage explaining the history of the lake and the ecological significance of the Green River and surrounding area. • Public Communication - NCWRC should clearly communicate project details and timelines with the public as plans are finalized. Thank you for your consideration of these comments and for the US Army Corps of Engineers oversight and guidance of this important project to protect public access to Lake Adger. Sincerely, � � 0 0 Gray Jernigan Southern Regional Director & Green Riverkeeper Wallace, Nancy L CIV USARMY CESAW (US) From: Wallace, Nancy L CIV USARMY CESAW (US) Sent: Tuesday, August 4, 2020 1:58 PM To: 'ronpeters@skyrunner.net' Cc: Brown, David W CIV USARMY CESAW (USA) Subject: SAW-2015-00788 (Lake Adger) On August 3, 2020 we received your public notice comments for file number SAW-2015-00788 and forwarded it to David Brown for further processing. Sincerely, Nancy Wallace USACE Wilmington District Asheville Regulatory Field Office 151 Patton Avenue RM 208 Asheville, NC 28801 828-271-7980 Ext 4221 nancy.wallace@usace.army.mil July 27, 2020 to 0 J 2gZD Mr. David Brown United States Army Corps of Engineers (USAGE) Wilmington District Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, NC 28801-5006 Re: Corps Action ID Number: SAW-2015-00788 Dear Mr. Brown, We understand the North Carolina Wildlife Resources Commission (NCWRC) is seeking Department of the Army authorization for 7.5 acres of permanent impacts to open waters (dredging and conversion to wetlands); 9.5 acres of temporary impacts to open waters (access and erosion control); 1.1 acres of permanent impacts to wetlands (fill); and 3.0 acres of temporary impacts to wetlands (access and erosion control), associated with dredging of the recreational navigation channel between the Lake Adger public boat access area and the lake's main channel adjacent to the Lake Adger Main Marina in Mill Spring, Polk County, North Carolina. The Lake Adger Property Owners Association, Inc. Board of Directors (LAPOABOD) recommends that USACE issue an authorization for the proposed work pursuant applicable procedures of Section 404 of the Clean Water Act. The LAPOABOD also reserves the right to comment on more detailed design speafications pertinent to the proposed dredging once they are developed by NCWRC or their c ontractor(s). Specific to the information provided, the LAPOABOD does offer the following comments: 1. Silt curtains should be installed around any area where active hydraulic dredging is occurring to reduce the potential for downstream resuspension of sediment. According to the plan, turbidity monitoring is only occurring twice daily and if an exceedance above 100 NTUs occurs, the plan does not call for dredging to stop until further control measures are put in place. 2. Downstream turbidity testing should continue at an interval of twice daily for the entire length of the project not just the first week as conditions can change due to weather related events. Ronald R. Peters, President, Board of Directors, Lake Adger Property owners Association, Inc. 839 Parkway North Road • 1411 Sprhq, NC 28756 • (828) 6254M • aural Labe .%4er 2 royerty owners .Association, Inc. Pqp12 3. The NCWRC should detail the anticipated timeframe the Lake Adger Main Marina and the recreational navigation channel may be off limits to the public. 4. We request that NCWRC consult with the LAPOABOD prior to the selection of the final plantings contained on page 14 of the plan to make certain any native species selected do not become invasive. If you have any questions regarding our comments, please do not hesitate to contact us. Thank you for considering our input. On behalf of the Lake Adger Property Owners Association, Inc., Ronald R. Peters President, Board of Directors Lake Adger Property Owners Association, Inc. RRP:smp cc: Mrs. Brittany Foulds, CMCA, Community Association Manager, IPM Corporation, P.O. Box 580, Arden, NC 28704 Ronald R. Palms, Prasident, Board of Dlrectom Lake Adger property owners Assocladon, Inc. 839 Parkway North Road a Mill Spring, NC M56 a (828) 6254M * wn o s fskYn nw-net Wallace, Nancy L CIV USARMY CESAW (US) From: Wallace, Nancy L CIV USARMY CESAW (US) Sent: Tuesday, August 4, 2020 1:55 PM To: itlecourt@hotmail.com Subject: SAW-2015-00788 (Lake Adger) On August 3, 2020 we received your public notice comments for file number SAW-2015-00788 and forwarded it to David Brown for further processing. Sincerely, Nancy Wallace USACE Wilmington District Asheville Regulatory Field Office 151 Patton Avenue RM 208 Asheville, NC 28801 828-271-7980 Ext 4221 nancy.wallace@usace.army.mil July 29, 2020 U 3 Mr. David Brown BY: United States Army Corps of Engineers (USACE) Wilmington District ----.. Asheville Regulatory Field Office 151 Patton Avenue, Rm. 208 Asheville, NC 28801-5006 Dear Mr. Brown, This is in response to the Public Comment requests being sought for SAW-2015-00788, concerning the application for Lake Adger Dredging Plans as submitted by North Carolina Wildlife Resources Commission (NCWRC). While we support the dredging of Lake Adger, these are our comments and concerns regarding this plan: 1. Concerning Cells B1 and C1— Protection of Culvert Between These Cells a. Placement and breakdown of these cell materials could over time clog or close off the drainage culvert running under Silver Creek Road. b. Clogging of this drainage culvert could directly create flooding of Polk County Tax Parcels #1— P54-199, #2 — P54-356, #3 — P54-132, and #4 — P54-133 as identified on Impacted Parcels presentation enclosed. c. Clogging of this drainage culvert could also result in flooding of Silver Creek Road at that point during heavy rain events that happen often. d. We request that this plan address this potential issue. 2. Concerning Cell Al — Approximate Area of Disturbance a. According to Plan C5, it appears that the upstream flow from the Green River will be negatively impeded from flowing into the Lake Adger. b. Water must not be -impeded from entering Lake Adger during this project which would negatively endanger wildlife and water quality. 3. Concerning Cell B1— Choking off Permanent Green River flow into Lake Adger a. There would appear to be some danger that Cell B1 will eventually close off the branch of flow nearest Silver Creek Road leaving only one feed into the lake. b. Concerns this reduction of flow will result in less turnover replacement of water in the lake resulting in stagnation, reduced lake levels, and degradation to the quality of the water. 4. Redirecting All Sediment Away from the Marina a. This plan appears to recommend redirecting all sediment to travel into the deeper middle channel of the lake. b. If allowed to occur, the sediment from upstream will then build up significantly in a new place. NCWRC is not under contract to have to dredge that portion of the lake. This would inevitably leave Polk County with the responsibility and expense of dredging. c. We request that Polk County Commissioners and citizens be made aware of this future impact before approval of application. S. Wetland Plantings a. We would request that Water Willow be removed from the wetland planting list. b. Polk County Commissioners are waiting on recommendation from Lake Adger POA citizens - On December 2, 2019, NCWRC requested Polk County Commissioners to allow planting of Water Willow into Lake Adger as a Test Site. The Commissioners deferred until Lake Adger Property Owners Board and its citizens can make a recommendation to the Commissioners. Due to COVID-19; efforts to inform citizens, investigate further, and make such recommendation to Commissioners has stalled. c. Willow Weed should not be introduced as part of this project. It is not native to Lake Adger. d. We request that this application not approve specific plant species. NCWRC should be required to consult stakeholders on final plantings. 6. Materials Used for Sediment Containment - Project Plan Description Page 4 a. On March 18, 2018, an original dredging plan was presented to Polk County Commissioners by NCWRC with approval by Polk County to proceed for permitting. b. On April 1,2019, NCWRC again appeared before the Polk County Commissioners to explain why the permitting submitted to the USACE one year earlier was not the correct permitting and new permitting application would have to be made. SAW-2015-00788 is the result. c. We request the original materials approved by the Commissioners for sediment containment be used as opposed to hay bales in the plan. Refer to Option 2 — In Water Replacement - Berm Construction Alternatives — Pg. 10 of March 18, 2018, NCWRC presentation enclosed. This would also somewhat address Concern #1 in this letter. 7. Public Meeting a. We request that a public meeting be held before application approval. b. Citizens were denied ability to ask questions of NCWRC following the March 18, 2019, presentation to Polk County Commissioners. c. Citizens were promised by then Commission Chair Melton an opportunity to question NCWRC once a new plan application was submitted. d. As USACE does not individually respond to concerns and comments sent to them as part of public comment, citizens were not previously allowed to ask questions, and a promise was made to the citizens that questions would be allowed once the plan was developed for USACE application submission; we believe a public meeting would benefit this project. Sincerely, d..44� 4404-f, I Irene and David LeCourt, 85 North Mountain Lane, Mill Spring, NC 28756 678-778-8065 — Mobile itlecourt@hotmaii.com mpacted Parcels �-R p IL -A4 .71 ,t . J .1, "', If Option 2 — In -water Placement • Wetland will be designed to • Ensure stability of placed material • Maintain hydraulic connection to the lake • Use cells for future channel maintenance dredging • Berm construction alternatives 1. Construct using rock 2. Construct using wood crib techniques 3. Construct using geotextile or HDPE liner 4. A combination of alternatives 1 through 3 • Design and construction considerations • Source of construction materials • On -shore staging during construction • Establishment of vegetation • Options for lake draw -down to aid construction NORTH CAROLINA RESOURCES COMMI551I1i. W Brown, David W CIV USARMY CESAW (USA) From: Jamie Davidson <jej56789@gmail.com> Sent: Monday, August 3, 2020 12:25 PM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] Corps Action ID Number: SAW-2015-00788 - Lake Adger Dredging - COMMENTS ATTACHED Attachments: Davidson Comments Lake Adger Dredging -Mountain True.docx Attached are my comments regarding the Lake Adger Dredging Plan. Thank you, Jamie Davidson Mr. David Brown USACE Wilmington District Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, North Carolina, 28801-5006 RE: Corps Action ID Number: SAW-2015-00788 Mr. Brown: I am commenting on the proposed plan to dredge the Lake Adger Marina. I am a full time resident of Lake Adger, owning lake front property since 2002. As a volunteer with Mountain True's Clean Water Team for 10 years and a past chair of the Lake Adger Lake Advisory Committee, I am, and have been for a long time, an advocate for clean water in Lake Adger. I agree with Mountain True's comments listed below but would like to add a few personal comments. Due to the fact that many Lake Adger residents did not directly receive notification of this plan nor the public comment until it was brought to our attention weeks after the announcement, I would like to stress the point that the Lake Adger residents should be kept informed of this plan, especially prior to the start of actual work being performed. Communication with the Lake Adger POA is essential. The section of the plan that I am most concerned with is the planting of Justicia Americana (water willow). In my research I have learned that this is considered a nuisance plant in some lakes and it is not native to Polk County. I do not want to see water willow, nor any other plantings that are not native to Polk County, planted in the waters of Lake Adger. Sediment Management, wetland construction methods, and habitat considerations are also of importance as detailed by Mountain True. I would like to add that I would hope that during this process, NCWRC would considered adding more recreational access for the public in the project area such as boardwalks, fishing piers, etc.. This would provide more citizen access and opportunities for educational programs for citizens to learn about the importance of wetlands. I think the plan developed by NCWRC for dredging is much needed and I hope all citizen comments will be taken into consideration. Below are the Mountain True comments in which I am in full agreement: MountainTrue has advocated for and supports this important project to protect public access to Lake Adger, since the public access channel has become nearly impassible to boat traffic due to the accumulating sediment delta. However, we have some suggestions to make this project as successful as possible and to ensure that water quality is protected during and after the project. Stakeholder Consultation — We request that NCWRC convene a stakeholder group consisting of parties to the lake management agreement (Polk County, Lake Adger Property Owners Association, Northbrook Energy), MountainTrue's Green Riverkeeper, and other interested parties like members of the fishing and boating community to receive feedback and input on the details of the project. These details would include timing, potential impacts to access and water quality, lake level fluctuations, and other concerns of public interest. Sediment Management — We appreciate the detailed turbidity monitoring protocols and support all efforts to control sediment impacts during and after the project. We suggest adding silt curtains around the dredging area, not just around the wetland construction area. Wetland Construction — We support the strongest and most protective methods to contain and dewater material used to construct wetlands. While hay bales may be cost effective to contain spoil material to form engineered wetlands, options like coir fiber biologs, geotubes, and others should be explored to ensure that the best available technology is incorporated into the project. NCWRC should specifically consider how high water events may impact constructed wetlands and how impacts can be mitigated. Wetland Planting — We request that Water Willow be removed from the wetland planting list. NCWRC is currently studying whether Water Willow is appropriate for introduction to Lake Adger, as it does not currently grow there. Following the precautionary principle, this plant should not be introduced as part of this project. Rather, NCWRC should continue its study and consult stakeholders on the potential future introduction of Water Willow. Habitat Considerations — Be mindful of aquatic and wetland wildlife habitat, especially fish spawning beds that can be affected by fluctuations in lake levels. Expanded Public Access Opportunities — NCWRC should consider opportunities to expand and improve public access and education in the project area, such as boardwalks, docks, fishing piers, and educational signage explaining the history of the lake and the ecological significance of the Green River and surrounding area. Public Communication — NCWRC should clearly communicate project details and timelines with the public as plans are finalized. Essommommommummunummmommmmmommmmmmmummommmmmommmmmmmmunnoommommmmmmmmmmmummummg Sincerely, Jamie Davidson Jej56789@gmail.com Brown, David W CIV USARMY CESAW (USA) From: Jamie Davidson <jej56789@gmail.com> Sent: Monday, August 3, 2020 11:31 AM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] Follow up request Mr. Brown: Do you have a copy of the Lake Adger wetland survey that I requested in my email below. Or, do you know how I can obtain a copy of this survey? Thank you, Jamie On Mon, Jul 27, 2020 at 11:03 AM Jamie Davidson <0e056789@gmail.com> wrote: Mr. Brown: We met Nov 18, 2018, when Gray Jernigan and I came to your office for a meeting regarding Lake Adger dredging. I have read the Lake Adger dredging plan and will comment on that in a separate email. I would like to request a copy of the Lake Adger wetland survey that is mentioned on Sheet io of io on the Plan below the plant listings. I have tried contacting Clearwater Environmental Consultants with no success or response. Below is information that was taken from the Plan (Sheet io of 1o) in regards to the Wetland Survey: NOTE: VEGETATION SPECIES AND WETLAND SEED MIXES LISTED IN TABLES 1 AND 2 ARE GENERALLY BASED ON THE INFORMATION COLLECTED DURING THE REFERENCE WETLAND SURVEY COMPLETED BY CLEARWATER ENVIRONMENTAL CONSULTANTS, INC., ON AUGUST 21-22, 2018. • Thank you in advance, Jamie Davidson Note new email address: ie156789@�mail.com Please change in your Contacts list. Jamie Davidson Brown, David W CIV USARMY CESAW (USA) From: schuylerconard@everyactioncustom.com on behalf of Sky Canard <schuylerconard@everyactioncustom.com> Sent: Sunday, August 2, 2020 6:08 AM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] Sky Conrad - PN Comments Lake Adger Dredging Dear Reg. Specialist David Brown, I am pleased to see that NC Wildlife Resources Commission (NCWRC) has submitted a permit application to dredge the public access channel at Lake Adger as it is obligated to do under the lake management agreement, and to use the dredge spoils to construct engineered wetlands on the existing sediment delta. I support this important project to protect public access to Lake Adger, since the channel has become nearly impassible to boat traffic due to sedimentation. I have some suggestions to make this project as successful as possible and to protect water quality during and after the project: Stakeholder Consultation - I request that NCWRC convene a stakeholder group consisting of parties to the lake management agreement (Polk County, Lake Adger Property Owners Association, Northbrook Energy), MountainTrue's Green Riverkeeper, and other interested parties like members of the fishing and boating community to receive feedback and input on the details of the project. These project details would include timing, potential impacts to access and water quality, lake level fluctuations, and other concerns of public interest. Sediment Management - I appreciate the detailed turbidity monitoring protocols and support all efforts to control sediment impacts during and after the project. I suggest adding silt curtains around the dredging area, not just around the wetland construction area. Wetland Construction - I support the strongest and most protective methods to contain and dewater material used to construct wetlands. While hay bales may be cost effective to contain spoil material to form engineered wetlands, options like coir fiber biologs, geotubes, and others should be explored to ensure that the best available technology is incorporated into the project. NCWRC should specifically consider how high water events may impact constructed wetlands and how these impacts can be mitigated. Wetland Planting - I request that Water Willow be removed from the wetland planting list. NCWRC is currently studying whether Water Willow is appropriate for introduction to Lake Adger, as it does not currently grow there. Following the precautionary principle, this plant should not be introduced as part of this project. Rather, NCWRC should continue its study and consult stakeholders on the potential future introduction of Water Willow. Habitat Considerations - Be mindful of aquatic and wetland wildlife habitat, especially fish spawning beds that can be affected by fluctuations in lake levels. Expanded Public Access and Educational Opportunities - NCWRC should consider opportunities to expand and improve public access and education in the project area, such as boardwalks, docks, fishing piers, and educational signage explaining the history of the lake and the ecological significance of the Green River and surrounding area. Public Communication - NCWRC should clearly communicate project details and timelines with the public as plans are finalized. Thank you for your consideration of these comments, and for the US Army Corps of Engineers' oversight and guidance of this important project to protect public access to Lake Adger. Sincerely, Sky Conard 49 Indian Summer Ln Mill Spring, NC 28756-4790 schuylerconard@gmail.com Brown, David W CIV USARMY CESAW (USA) From: dlconard@everyactioncustom.com on behalf of David Conard <dlconard@everyactioncustom.com> Sent: Sunday, August 2, 2020 5:36 PM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] Lake Adger Dredging Project: Request for Water Quality Protections, Better Public Access & More Dear Reg. Specialist David Brown, I am pleased to see that NC Wildlife Resources Commission (NCWRC) has submitted a permit application to dredge the public access channel at Lake Adger as it is obligated to do under the lake management agreement, and to use the dredge spoils to construct engineered wetlands on the existing sediment delta. I support this important project to protect public access to Lake Adger, since the channel has become nearly impassible to boat traffic due to sedimentation. I have some suggestions to make this project as successful as possible and to protect water quality during and after the project: Stakeholder Consultation - I request that NCWRC convene a stakeholder group consisting of parties to the lake management agreement (Polk County, Lake Adger Property Owners Association, Northbrook Energy), MountainTrue's Green Riverkeeper, and other interested parties like members of the fishing and boating community to receive feedback and input on the details of the project. These project details would include timing, potential impacts to access and water quality, lake level fluctuations, and other concerns of public interest. Sediment Management - I appreciate the detailed turbidity monitoring protocols and support all efforts to control sediment impacts during and after the project. I suggest adding silt curtains around the dredging area, not just around the wetland construction area. Wetland Construction - I support the strongest and most protective methods to contain and dewater material used to construct wetlands. While hay bales may be cost effective to contain spoil material to form engineered wetlands, options like coir fiber biologs, geotubes, and others should be explored to ensure that the best available technology is incorporated into the project. NCWRC should specifically consider how high water events may impact constructed wetlands and how these impacts can be mitigated. Wetland Planting - I request that Water Willow be removed from the wetland planting list. NCWRC is currently studying whether Water Willow is appropriate for introduction to Lake Adger, as it does not currently grow there. Following the precautionary principle, this plant should not be introduced as part of this project. Rather, NCWRC should continue its study and consult stakeholders on the potential future introduction of Water Willow. Habitat Considerations - Be mindful of aquatic and wetland wildlife habitat, especially fish spawning beds that can be affected by fluctuations in lake levels. Expanded Public Access and Educational Opportunities - NCWRC should consider opportunities to expand and improve public access and education in the project area, such as boardwalks, docks, fishing piers, and educational signage explaining the history of the lake and the ecological significance of the Green River and surrounding area. Public Communication - NCWRC should clearly communicate project details and timelines with the public as plans are finalized. This project has been long delayed and action is needed to protect this resource which the public has utilized intensively during the Covid times. Thank you for your consideration of these comments, and for the US Army Corps of Engineers' oversight and guidance of this important project to protect public access to Lake Adger. Sincerely, David Conard 49 Indian Summer Ln Mill Spring, NC 28756-4790 dlconard@yahoo.com Brown, David W CIV USARMY CESAW (USA) From: khummel@everyactioncustom.com on behalf of Kevin Hummel <khummel@everyactioncustom.com> Sent: Saturday, August 1, 2020 11:20 AM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] Kevin Hummel PC Comments Lake Adger Dredging Project: Request for Water Quality Protections, Better Public Access & More Dear Reg. Specialist David Brown, I am pleased to see that NC Wildlife Resources Commission (NCWRC) has submitted a permit application to dredge the public access channel at Lake Adger as it is obligated to do under the lake management agreement, and to use the dredge spoils to construct engineered wetlands on the existing sediment delta. I support this important project to protect public access to Lake Adger, since the channel has become nearly impassible to boat traffic due to sedimentation. I have some suggestions to make this project as successful as possible and to protect water quality during and after the project: Stakeholder Consultation - I request that NCWRC convene a stakeholder group consisting of parties to the lake management agreement (Polk County, Lake Adger Property Owners Association, Northbrook Energy), MountainTrue's Green Riverkeeper, and other interested parties like members of the fishing and boating community to receive feedback and input on the details of the project. These project details would include timing, potential impacts to access and water quality, lake level fluctuations, and other concerns of public interest. Sediment Management - I appreciate the detailed turbidity monitoring protocols and support all efforts to control sediment impacts during and after the project. I suggest adding silt curtains around the dredging area, not just around the wetland construction area. Wetland Construction - I support the strongest and most protective methods to contain and dewater material used to construct wetlands. While hay bales may be cost effective to contain spoil material to form engineered wetlands, options like coir fiber biologs, geotubes, and others should be explored to ensure that the best available technology is incorporated into the project. NCWRC should specifically consider how high water events may impact constructed wetlands and how these impacts can be mitigated. Wetland Planting - I request that Water Willow be removed from the wetland planting list. NCWRC is currently studying whether Water Willow is appropriate for introduction to Lake Adger, as it does not currently grow there. Following the precautionary principle, this plant should not be introduced as part of this project. Rather, NCWRC should continue its study and consult stakeholders on the potential future introduction of Water Willow. Habitat Considerations - Be mindful of aquatic and wetland wildlife habitat, especially fish spawning beds that can be affected by fluctuations in lake levels. Expanded Public Access and Educational Opportunities - NCWRC should consider opportunities to expand and improve public access and education in the project area, such as boardwalks, docks, fishing piers, and educational signage explaining the history of the lake and the ecological significance of the Green River and surrounding area. Public Communication - NCWRC should clearly communicate project details and timelines with the public as plans are finalized. i Thank you for your consideration of these comments, and for the US Army Corps of Engineers' oversight and guidance of this important project to protect public: access to Lake Adger. Sincerely, Kevin Hummel SECTION D LAKE ADGER Pkwy Lot 27 Mill Spring, NC 28756 khummel@bellsouth.net Brown, David W CIV USARMY CESAW (USA) From: marks74@everyactioncustom.com on behalf of Mark Smith <marks74 @everyactioncustom.com> Sent: Wednesday, July 29, 2020 9:01 PM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] Mark Smith PN Comments Lake Adger Dredging Project: Request for Water Quality Protections, Better Public Access & More Dear Reg. Specialist David Brown, I am pleased to see that NC Wildlife Resources Commission (NCWRC) has submitted a permit application to dredge the public access channel at Lake Adger as it is obligated to do under the lake management agreement, and to use the dredge spoils to construct engineered wetlands on the existing sediment delta. I support this important project to protect public access to Lake Adger, since the channel has become nearly impassible to boat traffic due to sedimentation. I have some suggestions to make this project as successful as possible and to protect water quality during and after the project: Stakeholder Consultation - I request that NCWRC convene a stakeholder group consisting of parties to the lake management agreement (Polk County, Lake Adger Property Owners Association, Northbrook Energy), MountainTrue's Green Riverkeeper, and other interested parties like members of the fishing and boating community to receive feedback and input on the details of the project. These project details would include timing, potential impacts to access and water quality, lake level fluctuations, and other concerns of public interest. Sediment Management - I appreciate the detailed turbidity monitoring protocols and support all efforts to control sediment impacts during and after the project. I suggest adding silt curtains around the dredging area, not just around the wetland construction area. Wetland Construction - I support the strongest and most protective methods to contain and dewater material used to construct wetlands. While hay bales may be cost effective to contain spoil material to form engineered wetlands, options like coir fiber biologs, geotubes, and others should be explored to ensure that the best available technology is incorporated into the project. NCWRC should specifically consider how high water events may impact constructed wetlands and how these impacts can be mitigated. Wetland Planting - I request that Water Willow be removed from the wetland planting list. NCWRC is currently studying whether Water Willow is appropriate for introduction to Lake Adger, as it does not currently grow there. Following the precautionary principle, this plant should not be introduced as part of this project. Rather, NCWRC should continue its study and consult stakeholders on the potential future introduction of Water Willow. Habitat Considerations - Be mindful of aquatic and wetland wildlife habitat, especially fish spawning beds that can be affected by fluctuations in lake levels. Expanded Public Access and Educational Opportunities - NCWRC should consider opportunities to expand and improve public access and education in the project area, such as boardwalks, docks, fishing piers, and educational signage explaining the history of the lake and the ecological significance of the Green River and surrounding area. Public Communication - NCWRC should clearly communicate project details and timelines with the public as plans are finalized. Thank you for your consideration of these comments, and for the US Army Corps of Engineers' oversight and guidance of this important project to protect public access to Lake Adger. Sincerely, Mark Smith 509 Silver Creek Rd Mill Spring, NC 28756-7626 marks74@windstream.net Brown, David W CIV USARMY CESAW (USA) From: lydia.wilson@everyactioncustom.com on behalf of Lydia Wilson <lydia.wilson@everyactioncustom.com> Sent: Wednesday, July 29, 2020 2:31 PM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] Lydia Wilson PN Comments Lake Adger Dredging Project: Request for Water Quality Protections, Better Public Access & More Dear Reg. Specialist David Brown, Hi! I use Lake Adger for relaxation and paddleboarding almost weekly. Thank you to the NC Wildlife Resources Commission (NCWRC) for submitting a permit application to dredge the public access channel at Lake Adger, even if is an obligation. The lake channels toward the Green River are getting hard to navigate due to the sediment. Would someone also look into the odd metal poles that stick up in the water on the river side? When levels are low, they seem dangerous. I support MountainTrue's below suggestions to make this project as successful as possible and to protect water quality during and after the project: Stakeholder Consultation - I request that NCWRC convene a stakeholder group consisting of parties to the lake management agreement (Polk County, Lake Adger Property Owners Association, Northbrook Energy), MountainTrue's Green Riverkeeper, and other interested parties like members of the fishing and boating community to receive feedback and input on the details of the project. These project details would include timing, potential impacts to access and water quality, lake level fluctuations, and other concerns of public interest. Sediment Management - I appreciate the detailed turbidity monitoring protocols and support all efforts to control sediment impacts during and after the project. I suggest adding silt curtains around the dredging area, not just around the wetland construction area. Wetland Construction - I support the strongest and most protective methods to contain and dewater material used to construct wetlands. While hay bales may be cost effective to contain spoil material to form engineered wetlands, options like coir fiber biologs, geotubes, and others should be explored to ensure that the best available technology is incorporated into the project. NCWRC should specifically consider how high water events may impact constructed wetlands and how these impacts can be mitigated. Wetland Planting - I request that Water Willow be removed from the wetland planting list. NCWRC is currently studying whether Water Willow is appropriate for introduction to Lake Adger, as it does not currently grow there. Following the precautionary principle, this plant should not be introduced as part of this project. Rather, NCWRC should continue its study and consult stakeholders on the potential future introduction of Water Willow. Habitat Considerations - Be mindful of aquatic and wetland wildlife habitat, especially fish spawning beds that can be affected by fluctuations in lake levels. Expanded Public Access and Educational Opportunities - NCWRC should consider opportunities to expand and improve public access and education in the project area, such as boardwalks, docks, fishing piers, and educational signage explaining the history of the lake and the ecological significance of the Green River and surrounding area. Public Communication - NCWRC should clearly communicate project details and timelines with the public as plans are finalized. Thank you for your consideration of these comments, and for the US Army Corps of Engineers' oversight and guidance of this important project to protect public access to Lake Adger. Sincerely, Lydia Wilson 222 Winners Cir Tryon, NC 28782-3762 lydia.wilson@gmail.com Brown, David W CIV USARMY CESAW (USA) From: jambey7@everyactioncustom.com on behalf of James Beyer <jambey7 @everyactioncustom.com> Sent: Wednesday, July 29, 2020 2:06 PM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] James Beyer PN Comments Lake Adger Dredging Project: Request for Water Quality Protections, Better Public Access & More Dear Reg. Specialist David Brown, I am pleased to see that NC Wildlife Resources Commission (NCWRC) has submitted a permit application to dredge the public access channel at Lake Adger as it is obligated to do under the lake management agreement, and to use the dredge spoils to construct engineered wetlands on the existing sediment delta. I support this important project to protect public access to Lake Adger, since the channel has become nearly impassible to boat traffic due to sedimentation. I have some suggestions to make this project as successful as possible and to protect water quality during and after the project: Stakeholder Consultation - I request that NCWRC convene a stakeholder group consisting of parties to the lake management agreement (Polk County, Lake Adger Property Owners Association, Northbrook Energy), MountainTrue's Green Riverkeeper, and other interested parties like members of the fishing and boating community to receive feedback and input on the details of the project. These project details would include timing, potential impacts to access and water quality, lake level fluctuations, and other concerns of public interest. Sediment Management - I appreciate the detailed turbidity monitoring protocols and support all efforts to control sediment impacts during and after the project. I suggest adding silt curtains around the dredging area, not just around the wetland construction area. 0 Wetland Construction - I support the strongest and most protective methods to contain and dewater material used to construct wetlands. While hay bales may be cost effective to contain spoil material to form engineered wetlands, options like coir fiber biologs, geotubes, and others should be explored to ensure that the best available technology is incorporated into the project. NCWRC should specifically consider how high water events may impact constructed wetlands and how these impacts can be mitigated. Wetland Planting - I request that Water Willow be removed from the wetland planting list. NCWRC is currently studying whether Water Willow is appropriate for introduction to Lake Adger, as it does not currently grow there. Following the precautionary principle, this plant should not be introduced as part of this project. Rather, NCWRC should continue its study and consult stakeholders on the potential future introduction of Water Willow. Habitat Considerations - Be mindful of aquatic and wetland wildlife habitat, especially fish spawning beds that can be affected by fluctuations in lake levels. Expanded Public Access and Educational Opportunities - NCWRC should consider opportunities to expand and improve public access and education in the project area, such as boardwalks, docks, fishing piers, and educational signage explaining the history of the lake and the ecological significance of the Green River and surrounding area. Public Communication - NCWRC should clearly communicate project details and timelines with the public as plans are finalized. Thank you for your consideration of these comments, and for the US Army Corps of Engineers' oversight and guidance of this important project to protect public access to Lake Adger. Sincerely, James Beyer Saluda, NC 28773 jambey7@yahoo.com Brown, David W CIV USARMY CESAW (USA) From: brucewhelchel@everyactioncustom.com on behalf of Bruce Whelchel <brucewhelchel@everyactioncustom.com> Sent: Wednesday, July 29, 2020 3:31 PM To: Brown, David W CIV USARMY CESAW (USA) Subject: [Non-DoD Source] Bruce Whelchel PN Comments Lake Adger Dredging Project: Request for Water Quality Protections, Better Public Access & Moreiiyiyiy Dear Reg. Specialist David Brown, I am pleased to see that NC Wildlife Resources Commission (NCWRC) has submitted a permit application to dredge the public access channel at Lake Adger as it is obligated to do under the lake management agreement, and to use the dredge spoils to construct engineered wetlands on the existing sediment delta. I support this important project to protect public access to Lake Adger, since the channel has become nearly impassible to boat traffic due to sedimentation. I have some suggestions to make this project as successful as possible and to protect water quality during and after the project: Stakeholder Consultation - I request that NCWRC convene a stakeholder group consisting of parties to the lake management agreement (Polk County, Lake Adger Property Owners Association, Northbrook Energy), MountainTrue's Green Riverkeeper, and other interested parties like members of the fishing and boating community to receive feedback and input on the details of the project. These project details would include timing, potential impacts to access and water quality, lake level fluctuations, and other concerns of public interest. Sediment Management - I appreciate the detailed turbidity monitoring protocols and support all efforts to control sediment impacts during and after the project. I suggest adding silt curtains around the dredging area, not just around the wetland construction area. Wetland Construction - I support the strongest and most protective methods to contain and dewater material used to construct wetlands. While hay bales may be cost effective to contain spoil material to form engineered wetlands, options like coir fiber biologs, geotubes, and others should be explored to ensure that the best available technology is incorporated into the project. NCWRC should specifically consider how high water events may impact constructed wetlands and how these impacts can be mitigated. Wetland Planting - I request that Water Willow be removed from the wetland planting list. NCWRC is currently studying whether Water Willow is appropriate for introduction to Lake Adger, as it does not currently grow there. Following the precautionary principle, this plant should not be introduced as part of this project. Rather, NCWRC should continue its study and consult stakeholders on the potential future introduction of Water Willow. Habitat Considerations - Be mindful of aquatic and wetland wildlife habitat, especially fish spawning beds that can be affected by fluctuations in lake levels. Expanded Public Access and Educational Opportunities - NCWRC should consider opportunities to expand and improve public access and education in the project area, such as boardwalks, docks, fishing piers, and educational signage explaining the history of the lake and the ecological significance of the Green River and surrounding area. Public Communication - NCWRC should clearly communicate project details and timelines with the public as plans are finalized. Thank you for your consideration of these comments, and for the US Army Corps of Engineers' oversight and guidance of this important project to protect public access to Lake Adger. Sincerely, Bruce Whelchel Columbus, NC 28722 brucewheichel@att.net