20200987 Ver 1_Time Ext Request_20200917

Strickland, Bev
From: Ferguson, Jeff C
Sent: Thursday, September 17, 2020 1:22 PM
To: Homewood, Sue; Yankura, Kaylie
Cc: Leslie, Andrea J; Loftis, C. Scott; Gardner, Gary; Robert Cork; 'Brown, David W SAW'
Subject: Lake Adger Dredging - 401 Request for Additional Information
Attachments: Lake Adger Navigation Channel Dredging -Sheet C5.pdf, 20200987 Ver 1-More Info
Requested_20200826.pdf, SAW-2015-00788 Lake Adger Dredging Request for
Additional Info Ltr Sep 2020.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
Hello Sue and Kaylie.
Following our Monday Teams meeting to discuss monitoring plans for the proposed dredging activities, I spoke with Rob
Cork of Anchor QEA about certain points that were raised and the timeline for providing the requested information.
Rob is amenable to modifying the limits of placement & habitat creation areas (shown on Sheet C5 of the 30%
drawing set) to eliminate any permanent impacts to the jurisdictional wetland areas. The lake bordering these
areas is typically very shallow. Separating the habitat creation areas from them should not significantly reduce
the capacity for placement of dredged material. Coir logs (rather than straw bales) would be staked to the lake
bed to provide a barrier between the placement and wetland areas. Some separation between the new habitat
features and the delineated wetlands between the JD limit and full pond elevation would also allow for inflow
between the existing and new wetland features at higher lake levels.
I asked Rob about the mapped temporary impacts (shown in green) between the JD limit and full pond
elevation. In the 30% plans, the intent was that some equipment access may be necessary for shaping and
grading of the placed material. Any of the temporarily impacted areas would be replanted. Rob indicated that
separating the placement areas from the existing wetlands would likely minimize any temporary
impacts. Details of the revised impact areas, placement/stabilization practices and BMPs would be provided
with the 60% plans.
Andrea, Scott and I have since met to work on the two monitoring plans. We should have drafts of the wetland
and turbidity monitoring plans for you to review next week. If you approve, we will have Rob's team work the
finalized plan details into the revised drawings.
The other additional information requested in items #2 & #4 involves providing a detailed phasing/construction
sequence plan and a statement pertaining to Division notification prior to future dredging & disposal
activities. Would it be possible to extend the DWR deadline for receipt of the requested additional information
so that it aligns with the December 31, 2020 deadline for additional information in the attached letter from
David Brown, USACE? This extension would help Anchor QEA make necessary modifications and incorporate the
monitoring components into a 60%+ plan set and narrative that will address both requests at once.
Thank you, and please feel free to contact me if you have any questions.
Regards,
Jeff

Jeff C. Ferguson, PE
Mountain Region Engineer
NC Wildlife Resources Commission
mailing address: 171 Southern Cross Rd.
Weaverville, NC 28787
mobile:[phone] H fax:[phone]
0eff.ferguson(cDncwildlife.org
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.

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MAXIMUM APPROXIMATE IMPACTED AREAS (ACRES)
IMPACT TYPE
AREA TYPE
DESCRIPTION
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31
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DREDGING
PERMANENT DUE TO
WETLAND
AREA BETWEEN FULL POND AND DOWNGRADIENT
0.7
0.4
>0.1
N/A
N/A
PLACED MATERIALS
WETLAND DELINEATION EXTENTS
PERMANENT DUE TO
OPEN WATER
AREA BETWEEN WETLAND DELINEATION EXTENTS
0.7
1.1
0.4
0.8
N/A
PLACED MATERIALS
AND CELL BOUNDARY
TEMPORARY BY
WETLAND
AREA BETWEEN FULL POND AND UPGRADIENT
1.3
1.7
N/A
N/A
N/A
CONSTRUCTION ACTIVITIES
LIMITS OF DISTURBANCE
TEMPORARY BY
AREA BETWEEN CELL BOUNDARY AND
CONSTRUCTION ACTIVITIES
OPEN WATER
DOWNGRADIENT LIMITS OF DISTURBANCE
1.8
4.5
LEGEND:
PROPOSED DREDGED MATERIAL
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PLACEMENT AREA DESIGNATION
EXAMPLE HAYBALE LOCATION
S
EXAMPLE SILT FENCE LOCATION
APPROXIMATE LIMITS OF
DISTURBANCE PLACEMENTAREA
14+00
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PROJECT STATIONING
NAVIGATION CHANNEL DREDGE
AREA APPROXIMATE EXTENTS
MITIGATION DREDGE AREA
APPROXIMATE EXTENTS
— • • —
APPROXIMATE LIMITS OF
DISTURBANCE
— — —
WETLAND DELINEATION
0
NORTH
0 80 160
SCALE IN FEET
NOTES:
1. PLACEMENT AREAS ARE APPROXIMATE,
CONTRACTOR TO INSTALL SEDIMENT CONTROL
FEATURES AS NEEDED TO CONTAIN SEDIMENT
WITHIN TARGET AREAS TO THE ELEVATIONS
SHOWN.
2. CONTRACTOR TO UTILIZE COMBINED HAYBALES,
SILT CURTAINS, OR OTHER CONTROL STRUCTURES
TO MANAGE SEDIMENTS WITHIN PLACEMENT AREA
EXTENTS.
3. CONTRACTOR MAY ADJUST ALIGNMENTS AS
NEEDED TO BALANCE PLACEMENT OPERATIONS
AND SEQUENCE THE WORK.
4. CONTRACTOR SHALL NOT BLOCK FLOW FROM
CULVERT AND GREEN RIVER BRANCHES DURING
MATERIAL PLACEMENT OPERATIONS.
5. ONLY BIODREGRADABLE FEATURES MAY BE LEFT IN
PLACE FOLLOWING MATERIAL PLACEMENT. ANY
SILT CURTAINS, ANCHORS, METAL STAKING, OR
OTHER INSTALLED ITEMS MUST OTHERWISE BE
REMOVED.
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6. CONTRACTOR MATERIAL TRANSPORT LINE SHOULD
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JAPPROVED
REVISIONS
DESIGNED BY: CORK,R.
DRAWN BY: HOLMER, D.
CHECKED BY: REEMTS, M.
BE: DIN (COLA, W.
SCALE: AS NOTED
DATE: JUNE 2020
NORTH CAROLINA WILDLIFE RESOURCES COMMISSION
7
C5
SHEET# 8 OF 10
REV
DATE
BY
AP P D
DESCRIPTION
LAKE ADGER NAVIGATION CHANNEL MAINTENANCE DREDGING
IMPACTED AREAS

DocuSign Envelope ID: B1 C6E6C2-2013-462E-A2C7-AB1 32C1 931 E2
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
August 26, 2020
DWR #20200987
Polk County
North Carolina Wildlife Resources Commission
Attn: Jeff Ferguson
1701 Mail Service Center
Raleigh NC 27699
Subject: REQUEST FOR ADDITIONAL INFORMATION
Lake Adger Channel Maintenance Dredging
Dear Mr. Ferguson:
On August 12, 2020, the Division of Water Resources — Water Quality Programs (Division) received your
application dated July 22, 2020, requesting a 401 from the Division for your 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 application notes that a wetland monitoring plan will be developed with input from the
resource agencies. Please provide the wetland monitoring plan. The monitoring plan should
include a detailed proposal for monitoring activities, a clear proposal for documentation and
determination of future evaluations of wetland function, and a mitigation to compensate for
any inadvertent loss of wetland function withing wetlands to be impacted with dredge material.
[15A NCAC 02H .0506(3)]
Please 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? [15A NCAC 02H
.0506(2)]
Please provide a more detailed and robust turbidity monitoring plan to ensure that water
quality standards will be maintained during in -water activities. [15A NCAC 02H .0506(2)]
4. 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
D E Q North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NpgTH C.AWi,!JNA
o.�ro�em m e�m��—W 111 ityl� 919.707.9000

DocuSign Envelope ID: B1 C6E6C2-2013-462E-A2C7-AB1 32C1 931 E2
North Carolina Wildlife Resources Commission
DWR Project #20200987
Request for Additional Information
Page 2of2
require updated jurisdictional determinations and/or NCWAM evaluations, and that updated.
[15A NCAC 02H .0506(1)]
Pursuant to Title 15A NCAC 02H .0502(c), the applicant shall furnish all of the above requested
information for the proper consideration of the application. Please respond in writing within 30
calendar days of receipt of this letter by submitting all of the above requested information through this
link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note the DWR# requested on
the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be denied as incomplete. The denial of this
project will necessitate reapplication to the Division for approval, including a complete application
package and the appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for this
activity and any work done within waters of the state may be a violation of North Carolina General
Statutes and Administrative Code.
Please contact Sue Homewood at 336-776-9693 or Sue. [e-mail] if you have any
questions or concerns.
Sincerely,
DocuSigned by:
949D91 BA53EF4E0...
Paul Wojoski, Supervisor
401 & Buffer Permitting Branch
cc: Robert Cook, P.E., Anchor QEA (via email)
David Brown, USACE Asheville Regulatory Field Office (via email)
Andrea Leslie, NCWRC (via email)
Byron Hamstead, USFS (via email)
DWR ARO 401 files
DWR 401 & Buffer Permitting Unit
20200987LakeAdgerDredging(Polk)_401_IC_Addinfo

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
September 14, 2020
Action ID: SAW-2015-007888
Anchor QEA of North Carolina, PLLC
Attn.: Robert Cork
231 Haywood Street
Asheville, NC 28801
Subject: Corps Comments and Request for Additional Information — Lake Adger Dredging
Project
Dear Mr. Cork:
Reference is made to your June 16, 2020, Department of the Army permit application
submitted on behalf of North Carolina Wildlife Resources Commission for the 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.
Based on our review of the application, supporting documents, and comments submitted by
supporting agencies and the public, the Corps is requesting additional information and providing
comments as follows:
1) Submit an alternative analysis.
Under the Section 404(b)(1), the alternative analysis requires the applicant to
demonstrate there are no practicable alternatives to the proposed discharge that would
have a less adverse effect on the aquatic environment. Noncompliance with this
requirement is sufficient basis for the Corps to deny the project permit. Also, the
unavailability of practicable alternatives does not necessarily result in issuance of a
permit. Compensatory mitigation cannot be used to satisfy the alternative analysis.
The applicant must demonstrate to the Corps that the proposed project is the least
environmental damaging practicable alternative (LEDPA) to achieve the project's
purpose. The 404(b)(1) guidelines requires selecting the LEDPA, provided it does not
result in greater adverse environmental consequences. No discharge of dredge or fill
material shall be permitted if there is a practicable alternative to the proposed
discharge which would have less adverse impacts on the aquatic ecosystem, so long
as the alternative does not have other significant adverse environmental
consequences.
Alternatives must be practicable, feasible, and accomplish the project's purpose and
need. An alternative is practicable if it is available and capable of being done taking

into consideration cost, existing technology, and logistics in light of overall project
purpose.
Alternatives not involving discharges into special aquatic sites are presumed available
and have less adverse impact on aquatic ecosystem, unless clearly demonstrated
otherwise. Special aquatic sites are sanctuaries and refuges; wetlands; mud flats;
vegetated shallows; coral reefs; and riffle and pool complexes.
The analysis must include the no action alternative, the proposed project, and a
sufficient number of alternatives to demonstrate the applicant has considered
alternatives to the proposed project which may impact more or less aquatic resources.
The analysis should clearly state each alternative and document the rational and
findings of each alternative. Each alternative should state the extent of impacts to
aquatic resources, effects to federally protected species and historic properties,
estimated cost, and summarize the construction methodology and logistics.
Based on the submitted information for the proposed project, the Lake Adger
dredging project is considered water dependent by the Corps. The activity does
require access or proximity to or sitting within special aquatic sites (wetlands) which
are within the Corps' project Area. Therefore, you will not need to look at off -cite
alternatives in your analysis.
2) Provide final design and plans for the dredging and spoils disposal activities. The
plans need to include a vegetation monitor plan for the new or enhanced wetlands of
the spoils disposal areas. The plans should include the estimate volume of dredged
material for the initial dredging episode and the expected volumes for future
maintenance dredging episodes.
3) Provide an evaluation and discussion of the existing conditions of the aquatic
resources proposed to be impacted and how these resources will change based on the
proposed project.
4) The project is located within the FEMA designated 100-year floodplain. The project
must comply with applicable FEMA-approved state and local floodplain management
requirements. Provide a copy of the approved FEMA permit or other documentation
that indicate the project meets these requirements.
The Corps is considering the permit expiration to be 25 years after issuance, with the
initial dredging episode to be conducted within 36 months after issuance and future
maintenance dredging to be conducted as needed.
5) Provide a schedule for the dredging and disposal area activities for the initial episode
of dredging and an estimate of how often future dredging activities will be conducted.
Please submit the above requested information by December 31, 2020. Once the Corps
receives the information, a meeting with NCWRC, NCDEQ-DWR, and the Corps may be
appropriate in order to review and discuss the information submitted. In order to aid in NCDEQ-
DWR's 401 permit process for this project, please copy Sue Homewood with NCDEQ-DWR on
your document to be submitted to the Corps. If you have any questions please contact me.

Sincerely,
�1
David Brown, PG
Regulatory Specialist/Geologist
Asheville Regulatory Field Office
Copy (by email):
NCDEQ-DWR - Sue Homewood, [e-mail]
NCWRC - Andrea Leslie, [e-mail]
NCWRC - Jeff Ferguson, [e-mail]