20070165 Ver 2_More Info Received_20100312

CLEARWATER ENVIRONMENTAL CONSULTANTS, INC.
March 11, 2010
Mr. Ian McMillan
NC Division of Water Quality
1650 Mail Service Center
Raleigh, North Carolina 27699
k§@g0W1RB
1-JAR 1 L 2010
RE: Request for More Information WETLANDS AND MIMATERBWCH
Grandview Peaks
McDowell County, North Carolina
Action ID SAW-2007-200-359; DWQ Project # 07-0168 Ver. 2
Dear Mr. McMillan,
Please reference the letter dated February 15, 2010 (Attachment A) sent by the NC
Division of Water Quality (DWQ) in response to the permit application submitted by
C1earWater Environmental Consultants, Inc. (CEC), on behalf of Mr. Todd Black of Fall
Creek Land Company. The permit application requested written authorization for the
impacts associated with development of the Grandview Peaks residential subdivision and
associated infrastructure including amenities lakes. The comments provided by the DWQ
are listed and discussed below.
DWQ Comment #1: "On page 17, the applicant states, `The proposed lakes will not be
located in streams that contain migrating or spawning fish.' Please provide
documentation of any studies or data collected that indicate that no fish species spawn in
the stream segments proposed for impacts."
After review of the permit application, CEC understands that the statement made
on page 17 of the permit application is unclear. The application attempted to
paraphrase a guideline from the NC Wildlife Resources Commission (WRC)
Instream Impoundment Guidelines (July 2006). The guideline states: "Upstream
and downstream passage of aquatic organisms may be warranted and should be
reviewed on a case by case basis and viewed in the context of the watershed
condition." The intent of the statement in the application was to say that the dams
will not be located in streams that contain fish that necessitate migration to spawn
(such as species targeted for fish passage structures including salmon, trout,
sturgeon, striped bass, herring and shad). Stream channels on site may contain
spawning fish; however, because they do not have to migrate in order to spawn,
presence of a dam will not inhibit those species. Because of this conclusion, the
dam will not be designed with a fish passage structure.
718 Oakland Street
Hendersonville, North Carolina 28791
Phone: [phone] Fax: [phone]
www,cwenv.com
Mr. Ian McMillan
03.11.10
Page 2 of 8
DWQ Comment #2: "Also on page 17, the applicant states that if at some point during
their proposed 5 -year monitoring program that if water quality parameter measurements
are found to be unsatisfactory by the DWQ, the applicant will submit a contingency plan
to return water quality parameters to satisfactory levels. How [does the applicant]
propose to do this and what will this contingency plan consist op"
The dam and impoundment will be designed to maintain existing water quality
standards. It is the intent of the applicant to have a working and functioning
impoundment that does not violate water quality standards. However, if water
quality standards are exceeded a contingency plan will be submitted to return
water quality standards to acceptable levels. At this time, it is impossible for the
applicant to determine which if any water quality standards would be violated and
to what degree. Without guidance from the DWQ regarding which water quality
standards are of the greatest concern, the applicant can only make general
statements about activities that may be used to maintain and bring water quality
standards back into compliance. The dams will be designed with an outflow that
aerates water released from the dam. Because of this, the applicant does not
anticipate that dissolved oxygen parameters will be violated. The dam designs are
also going to include a cold water release. Installation of a cold water release will
decrease and/or eliminate increased water temperatures downstream of the lakes.
Dissolved gasses can increase due to nuisance vegetation growth. In this
situation, herbivore fish may be introduced to aid in control of nuisance
vegetation. Violation of chlorophyll-a standards may be corrected through the
implementation of restrictive covenants which limit or restrict the use of
fertilizers and other nutrients for lawn maintenance, if that is found to be the
cause.
Additionally, the applicant is proposing a Lake Management Plan prepared by a
Certified Lake Manager. The plan will include discussions and recommendations
for the items such as sediment, depth, water quality, vegetation, algae, fisheries,
boating types and usage, capital improvements, and maintenance.
Recommendations for maintaining water quality standards will be a part of this
plan.
The dams have not been designed and a Lake Management Plan has not been
completed to date. The applicant feels that these tasks will take a significant
expenditure of resources and is not prepared to complete these tasks without some
assurance that the project will be approved. Requesting a contingent 401 Water
Quality Certification for the project is similar to previously approved lake projects
such as Traditions and the Ridge at South Mountain.
DWQ Comment #3: "The applicant proposes to do a combination of on-site
preservation and paying into EEP. The total mitigation need is 7, 580 stream credits.
[The applicant is] proposing preservation of 62, 000 LF of stream at a 9:1 to provide
6,885 stream credits, and paying the balance to EEP for 695 feet. The 2003 Interagency
Stream Mitigation Guidelines indicate the ratio for preservation is 10:1. At 10:1,
Mr. Ian McMillan
03.11.10
Page 3 of 8
preservation would yield 6,200 stream credits. Combined with the proposed purchase of
695 credits, [the applicant] still has a deficit of 685 credits. The total credits obtained
from EEP should be 1, 380 credits."
The mitigation plan proposed by the applicant is in accordance with DWQ
guidelines and the Stream Mitigation Guidelines (2003). DWQ mitigation
requirements regarding the construction of impoundments are clearly stated in the
DWQ memo dated August 19, 2002. The memo states: "Compensatory stream
mitigation will not be required by DWQ for the impact due to flooding." The
mitigation plan as proposed meets DWQ criteria. Dam impacts at the site total
695 linear feet and the applicant is proposing payment into the EEP for 695 linear
feet to compensate for these impacts.
Additionally, the Stream Mitigation Guidelines (2003) specifically state in Table
2 on page 13 that the mitigation ratio required for preservation is 2.5:1 to 5:1.
The applicant has proposed a 9:1 ratio which is above and beyond what is
required by the guidelines; the applicant has proposed an additional 27,575 linear
feet (5 miles) of preservation, beyond what is in compliance with the mitigation
guidelines, for this project.
The applicant believes the mitigation proposed in the permit application meets or
exceeds all guidelines set forth by the US Army Corps of Engineers (Corps) and
the DWQ.
DWQ Comment #4: "During the pre-application meeting held at the DWQ-Asheville
Regional Office on November 30, 2009, the applicant stated that post construction
maintenance of the proposed dams and impoundments will be the responsibility of the
Grandview Peaks Homeowners Association. Since the applicant has acknowledged that
the proposed dams will be considered "High Hazard" dams by the Division of Land
Resources-Dam Safety Unit, this office will need to review very specific details of this
arrangement, especially in light of the dam failure at Balsam Mountain."
The applicant is aware of the Dam Safety Unit's permit requirements. Upon
issuance of the DWQ water quality certification, the applicant will submit plans,
specifications, design data, and appropriate calculations prepared by a
professional engineer to the Division of Land Resources (DLR) for review and
approval through the Dam Safety Unit. The DWQ is encouraged to communicate
and work closely with the DLR during the review and approval process. To
facilitate this communication, the applicant will copy the DWQ on all
correspondence to the DLR relating to the construction of the dam.
DWQ Comment #5: "For the record, it should be noted that the DWQ returned the
previous application because the applicant's agent did not submit the information DWQ
had requested by the extended date the agent had requested. Additionally, it is the
understanding of this Office that the applicant chose to withdraw his previous permit
application because if he had not, the USACE was moving towards denial of the permit
Mr. Ian McMillan
03.11.10
Page 4 of 8
request. Faced with these facts, it is unclear how the applicant believes this virtually
identical permit request will be approved. Please explain how this permit request is
significantly different from the previous one."
The applicant is aware that the DWQ returned a previous application for this
project. The applicant is also aware that there were communication issues
between the applicant's previous consultant and the DWQ. Following the return
of the application by the DWQ, the applicant met individually with Mr. Scott
Jones of the Corps. Based on a number of factors, the applicant made the
decision to withdraw the still pending application with the Corps and begin the
process again.
The previous application was not returned and withdrawn because of the nature of
the project. It was returned and withdrawn because the Corps and DWQ were not
provided with answers to pertinent project questions; this is an important
distinction.
Although the project is very similar, the application and information provided is
vastly different. CEC identified major deficiencies in the previous permit
application and correspondence and has worked diligently with the applicant to
provide information not included in the previous application. Although not all of
the differences can be identified in this letter, the most important differences are
discussed below.
Purpose and Need - Defining the project purpose is critical to the evaluation of
any project. The previous permit application indicated a project purpose that only
included the construction of on-line impoundments. This type of purpose
statement is unacceptable because it significantly limits the alternatives analysis.
CEC has significantly redefined the purpose and need statement on behalf of the
applicant. Additionally, the previous permit application tried to cloak the lakes
true purpose (aesthetics and recreation) behind fire suppression, irrigation, and
fisheries creation. CEC and the applicant have represented the ponds as they are
intended to function in the development.
Alternatives Analysis - A complete alternatives analysis is required for permit
review. The previous application did not include a complete alternatives analysis
for this project. The newly submitted permit application includes an extensive
alternatives analysis that discusses the residential development as well as different
types of amenities.
Mitigation - A mitigation plan that offsets project impacts must be proposed.
The previous application failed to include a mitigation plan in accordance with
Corps and DWQ guidelines. The newly submitted permit application includes a
clear and concise mitigation plan that is in compliance with mitigation guidelines
set forth by the Corps and DWQ.
Mr. Ian McMillan
03.11.10
Page 5 of 8
Water Quality Sampling - The DWQ requested analytical monitoring based on
the Predictability Study Protocol for Sampling Referenced Impoundments. In-
lieu of the Predictability Study, the applicant's previous consultant proposed a
form of watershed modeling. The DWQ and previous consultant could not come
to an agreement regarding this approach. The newly submitted permit application
includes a plan for water quality monitoring and sampling following the
Predictability Study guidelines along with data from two reference
impoundments.
The applicant expects the DWQ and the Corps to review this application on its
own merit.
DWQ Comment #6: "Please submit a specific minimum water release plan for the
proposed dam. The plan must include a written explanation of the specific discharge rate
and mechanism to provide for each required release. The plan must also include any
design specifications, details and calculations to show that the release shall be achieved
in the given conditions. Specifically, this Office would like the applicant to propose
minimum water release for this project, other than minimum 7Q10 which may not be
sufficient to protect downstream water quality. The plan shall also include monitoring
that ensures compliance. The plan and any associated facilities, once approved, must be
in place and implemented upon completion of the dam."
The design for the dams has not been completed to date. The applicant feels that
this task will take a significant expenditure of resources and is not prepared to
complete this task without some assurance that the project will be approved. This
approach to the project is similar to previously approved lake projects such as
Traditions and the Ridge at South Mountain.
As requested by the DWQ, a minimum water release plan will be included with
the dam designs. The DWQ has recently issued several 401 Water Quality
Certifications and in those projects the 7Q10 minimum flows have been
acceptable to the DWQ. The applicant questions the request to deviate from that
standard. If some other low flow requirement is to be required by the DWQ, the
applicant requests further information and guidance from the DWQ regarding this
requirement.
DWQ Comment #7: "Please provide plans at the 1 "=100' scale clearly showing which
lots are sold and please place building envelopes on all lots that contain wetlands or
streams."
A permit map indicating which lots have been sold is included for review (Figure
1). Based on a conversation between Ms. Rebekah Newton of CEC and Mr. Ian
McMillan of the DWQ on February 26, 2010, the applicant will not be providing
building envelopes for each lot with streams and wetlands. As the project is
proposed, 82% of streams and 68% of wetlands are being preserved on site. The
majority of streams and all wetlands not preserved include those reaches and areas
Mr. Ian McMillan
03.11.10
Page 6 of 8
that are proposed for impact. After factoring in impacts, 91 % of remaining
streams and 100% of remaining wetlands will be preserved on site. Impacts will
not be allowed in these areas and home owners will be required to abide by a
setback of 30 or 60 feet adjacent to preserved streams as shown on the permit
map. Because stream buffers are already indicated on the permit map, providing
building envelopes does little in the way of providing additional information for
the project. The vast majority of unpreserved streams are located at the entrance
to the development. These waters are classified as "C" waters by the DWQ.
Waters with a class "C" designation and wetlands are not required to have buffers.
Under DWQ regulations, property owners are not required to abide by a set back
in these areas. With that in mind, providing a building envelope on these lots,
which would become a part of the permit authorization, constitutes upland
preservation without credit to the applicant. All lots within the development are
buildable without additional impacts to streams and wetlands. If the DWQ has
concern about specific lots, the applicant can address those lots specifically.
DWQ Comment #8: "As noted by the US Fish and Wildlife Service in the previous
permit application, the Grandview Peaks website does not mention any onsite amenity
ponds and the only reference to lakes is a mention of nearby lakes. This in light of the
current completed sales of many of the onsite lots, it appears amenity lakes are not a
selling point of this development."
Lakes are very much a selling point of this development for the reasons stated in
the application; however, because the lakes have not been approved for
construction and the applicant cannot ensure their construction, officially
advertising them on the website might be considered misrepresentation and might
be illegal. Prospective customers who visit the development are informed about
the lakes as were people who have already purchased lots in the subdivision.
Regulations governing interstate land sales limit what may be advertised about a
development to the general public. To keep lot owners up to date on the lake
proposal and approval process, a copy of the permit application is available at the
sales office located within the development. Although they cannot be and are not
officially advertised, the lakes are an integral part of this community.
DWQ Comment #9: "Page 34 of the application narrative states, `...when the lake is the
primary amenity, lot values become heavily dependent on its presence, and the value of
lots on or in close proximity of the lake see a substantial increase in value.' How did
[the applicant] determine this? This position runs contrary to a recent study conducted
by the University of Wisconsin-Madison - Department of Agricultural & Applied
Economics, dated July 2007."
CEC and the applicant appreciate the information provided by the DWQ in
regards to the aforementioned study from the University of Wisconsin. As is
common in academia, journal articles and studies with refuting information can
often be found to counter findings that are made regarding a specific subject. The
University of Wisconsin Staff Paper is no different. A quick internet search of
Mr. Ian McMillan
03.11.10
Page 7 of 8
journal articles yielded two very similar articles by Notie H. Lanford, Oklahoma
State University, and Lonnie L. Jones, Texas A&M University entitled
"Recreational and Aesthetic Value of Water Using Hedonic Price Analysis" and
"Marginal Price of Lake Recreation and Aesthetics: An Hedonic Approach" both
dated 1995. These articles conclude that housing around a lake commands a
premium price and that price falls, in some cases as much as 40% (depending on
distance) as houses move away from a lake.
In-lieu of the applicant and the agencies continuing in an exchange of information
that supports or refutes academic and journal articles, the applicant offers the
following information. Because of the cost of construction, lakes would not be
proposed unless there was significant benefit to their construction, and the cost
could be recovered. An analysis of online data for parcels in the vicinity of
Cardinal Lake in Transylvania County yielded the following information. There
are 36 parcels adjacent to Cardinal Lake. Tax record information included sale
prices for 27 of the 36 parcels. The mean sale price for homes or lots
immediately adjacent to the lake is $1,789,984, with a high cost of $3,500,000
and a low cost of $5,000. For comparison purposes, 36 parcels were chosen that
were not immediately adjacent to Cardinal Lake but that were immediately
adjacent to the golf course at the Toxaway Country Club. These parcels are of
similar size to those around the lake. Tax record information included sale prices
for 23 of the 36 parcels. The mean sale price for these homes or lots, according to
data provided by Transylvania County is $321,021, with a high cost of $1,250,000
and a low cost of $31,000. For a second comparison, 36 parcels of similar size to
those around the lake and adjacent to blue-line streams were chosen. Streams
adjacent to chosen parcels included the Toxaway River, unnamed tributaries to
Cardinal Lake, unnamed tributaries to Lake Toxaway, Indian Creek, and unnamed
tributaries to Indian Creek. Multiple streams were chosen because not one
tributary yielded 36 lots or homes for comparison. Tax record information
included sale prices for 27 of the 36 parcels. The mean sale price for homes or
lots immediately adjacent to the tributaries, according to data downloaded from
Transylvania County is $175,025, with a high cost of $900,000 and a low cost of
$7,500. Although this price comparison is not scientific in nature, it does indicate
that prices for lots and homes adjacent to the lake have a higher cost. The cost
spread would be more significant provided the homes and lots used for
comparison were not adjacent to an amenity (i.e. golf course).
The applicant is confident that this comparison could be done for any community
comprised of a lake and yield similar results. Please note, McDowell County and
Rutherford County parcel data is not available for download online and at the
writing of this letter, requested parcel data from McDowell and Rutherford
County was not supplied.
Mr. Ian McMillan
03.11.10
Page 8 of 8
DWQ Comment #10: "Please provide an inventory of imperviousness surfaces in each
drainage area. The inventory should include all proposed building footprints, road,
driveways, sidewalks, gravel surfaced area, amenity areas, etc. A Stormwater
Management Plan (SMP) must be provided for any drainage areas that exceed 24
percent imperviousness. For each BMP, provide a completed BMP Supplement Form
with all the required items."
For the purpose of determining impervious surface area, several worst case
assumptions were made; the calculation assumes 1) all houses are ranches and
have a footprint of 4,000 square feet, 2) all lots are 1 acre, 3) all driveways are
paved and 12 feet x 200 feet (2,400 square feet), and 4) roads are 20 feet in width.
With these assumptions, the following calculations have been made:
Building 2,055 lots x 4,000 sq. ft. 189 acres
Driveway 2,055 lots x 2,400 sq. ft. 114 acres
Roads 20 mi x 20 ft wide 49 acres
Total Impervious Area 352 acres
Given the assumptions and calculations above, the total percentage of impervious
area at the site would be 17%. This is a highly bias figure because only 760 lots
are proposed (ranging from approximately 1 acre to 14 acres) for the development
and ranch-style homes with a square footage of 4,000 square feet are extremely
unlikely (homes of this size would be constructed on multiple levels reducing the
footprint on the ground and size of the roof); however, the worst case scenario is
demonstrated here to show that a density of almost 3 times what is proposed
would still not yield impervious surface areas close to 24%.
The applicant believes the information submitted in this package addresses all issues set
forth by the DWQ in their letter dated February 15, 2010. Should you have any questions
or comments concerning this project please do not hesitate to contact me at 828-698-
9800.
Sincerely,
-f C2 n G?,A-
Rebekah L. Newton
Project Biologist
R. Clement -d e,
Principal
Attachment A
DWQ Response to Public Notice
(dated February 15, 2010)
?1
-AN;
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
February 15, 2010
Dee Freeman
Secretary
DWQ Project # 07-0168, Ver..2
McDowell County:
CERTIFIED MAIL: RETURN RECEIPT REQUESTED
Mr. Todd Black
Fall Creek Land Company
P.O. Box 638
Hickory, NC 28603
Subject Property: Grandview Peaks Recreational Lakes
Shoal Creek [030802, 9-41-12-1, WSV]
Kelly Branch [030802, 9-41-12-2, WSV]
Weaver Branch [030802, 9-41-12-1-1, WSV]
REQUEST FOR MORE INFORMATION
Dear Mr. Black:
CEC Project i WOZ
Da!e Recleved pZ ?18t'd
On December 17, 2009, the Division of Water Quality (DWQ) received your application dated December'
10, 2009, with Public Notice issued by the USACE on January 12, 2010, and received by the DWQ
January 12, 2010, to fill or otherwise impact 0.73 acres of 404/wetland (0.04 acres dam fill, and 0.69
acres flooding), and 695 linear feet of stream (dam fill), and flood 5,970 linear feet of stream, to construct
two aesthetic lakes within the Grandview Lakes residential development. The DWQ has determined that
your application was incomplete and/or provided inaccurate information as discussed below. The DWQ
will require additional information in order to process your application to impact protected wetlands
and/or streams on the subject property. Therefore, unless we receive three copies of the additional
information requested below, we will place this project on hold as incomplete until we receive this
additional information. If we do not receive the requested information, your project will be formally
returned as incomplete. Please provide the following information so that we may continue to review your.
project.
Additional Information Requested:
1. On page 17, the applicant states, "The proposed lakes will not be located in streams that contain
migrating or spawning fish." Please provide documentation of any studies or data collected that
indicate that no fish species spawn in the stream segments proposed for impact.
2. Also on page 17, the applicant states that if at some point during their proposed 5-year.monitoring
program that if water quality parameters measurements are found to be unsatisfactory by the
DWQ„ the applicant will submit a contingency. plan to return water quality parameters to
satisfactory levels." How do you propose to do this and what will this contingency plan consist
of?
3. The applicant proposes to do a combination of on-site preservation and paying into EEP.
401 OversightlExpress Review Permitting Unit One I
1650 Mail Service Center, Raleigh, North Carolina 27699-1650 NorthCarohna
Location: 2321 Crabtree Blvd., Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Na&&4
Internet: http://h2o.enr.state.nc.us/ncwetlands/ An Equal Opportunity 1 Affirmative Action Employer

Mr. Todd Black and Fall Creek Land Company
Page 2 of 2
February 15, 2010
The total mitigation need is 7,580 stream credits. They are proposing preservation of 62,000 LF
of stream at 9:1 to provide 6,885 stream credits, and paying the balance to EEP for 695 feet. The
2003 Interagency Stream Mitigation Guidelines indicate the ratio for preservation is 10:1. At
10:1, preservation would yield 6,200 stream credits. Combined with the proposed purchase of
695 credits, they still have a deficit of 685 credits. The total credits obtained from EEP should be
1,380 credits.
4. During the pre-application meeting held at the DWQ-Asheville Regional Office on November 30,
2009, the applicant stated that post construction maintenance of the proposed dams and
impoundments will be the responsibility of the Grandview Peaks Homeowners Association.
Since the applicant has acknowledged that the proposed dams will be considered "High Hazard"
damn bythe Division of Land Resources - Dam Safety Unit, this office will need to review very
specific details of this arrangement, especially in light of the dam failure at Balsam Mountain.
5. For the record, it should be noted that DWQ returned the previous application because the
applicant's agent did not submit the information DWQ had requested by the extended date the
agent had requested. Additionally, it is the understanding of this Office that the applicant chose
to withdraw his previous permit application because if he had not, the USACE was moving
towards denial of the permit request. Faced with these facts, it is unclear how the applicant
believes this virtually identical permit request will be approved. Please explain how this permit
request is significantly different from the precious one.
6. Please submit a specific minimum water release plan for the proposed dam. The plan must
include a written explanation of the specific discharge rate and mechanism to provide for each
required release. The plan must also include any design specifications, details and calculations to
show that the release shall be achieved in the given conditions. Specifically, this Office would
like the applicant to propose minimum water:release for this project, other that minimum 7Q10
which may not be sufficient to protect downstream water quality. The plan shall also include
monitoring that ensures compliance. The plan and any associated facilities, once approved, must
be in place and implemented upon the completion of the dam.
7. Please provide plans at a 1'=100' scale clearly showing which lots are sold and please place
building envelopes on all lots that contain wetlands or streams.
8. As noted by the U.S. Fish & Wildlife Service in the previous permit application, the Grandview Peaks
website does not mention any onsite amenityponds and the only reference to lakes a mention of
nearby area lakes (website: hn://www.falicreektand.com/GrandviewPeaks/tabid/57/Default.g x).
This in light of the current completed sales of many of the onsite lots, it appears amenity lakes are not
a selling point of this development.
9. Page 34 of the application narrative states, when the lake is the primary amenity, lot values
become heavily dependent on its presence, and the value of lots on or in close proximity of the lake
see a substantial increase in value." How did you determine this? This position runs contrary to a
recent study conducted by the University of Wisconsin-Madison - Department of Agricultural &
Applied Economics, dated July 2007, regarding the effects of dam removal on small lake
communities which found the following:
The general conclusions of this research are:.
• Shoreline frontage along small impoundments (ponds) does not notably increase
residential property value compared to frontage along free-flowing rivers.
Mr. Todd Black and Fall Creek Land Company..
Page 3 of 3
February 15, 2010:.
• Residential property located near a free-flowing river is more valuable than identical
property located near an impoundment (pond). Our research estimated that property
along a free-flowing river would be worth, on average, $14,000 more than a similar
property at the site of a recently removed dam or current impoundment (pond).
• The results also indicate that removing a dam does little harm to property values in
the short run (2 years in the study), and helps increase property values in the long
run, as the stream and the area along it return to a "natural" free-flowing state, or are
managed as a desirable open space: such as a park.
While this research focused on a single housing market in a relatively small area, the basic
messages of these results apply to other locations as well. The study focused on communities
that had relatively small ponds, and the results may not apply to large impoundments where
recreational activities like fishing, boating and swimming are well established.
Based on what our research found, we would expect that properties that lose their frontage on
impoundments would not decrease in value, and may in fact increase in value as their
frontage converts to frontage on a river. The value of properties that no longer have water
frontage after a dam removal depends on what replaces the area of the former impoundment.
Often, such a riverside public "greenbelt" replaces the impoundment. Studies indicate open
space increases the housing values of adjacent properties, particularly if the open space is
dedicated to nature preservation and passive experiences, such as hiking and birdwatching.
Link: htto://www.wisconsinrivers or index 12hp?page=content&mode=view&id=6
10. Please provide an inventory of imperviousness surfaces in each drainage area. The inventory should
include all proposed building footprints, roads, driveways, sidewalks, gravel-surfaced areas, amenity
areas, etc. A Stormwater Management Plan (SMP) must be provided for any drainage areas that .
exceed 24 percent imperviousness. For each BMP, provide a completed BMP Supplement Form with'
all the required items (see hqp://h2o.enr.state.nc.us/su/bmp forms htm). Per NCAC 2B 15A:
02H.1000, a "drainage area" is defined as "the entire area contributing surface runoff to a single
point."
Please submit this information or otherwise address this request within 30 calendar days of the'date of this:
letter. If we do not receive this requested information within 30 calendar days of the date of this letter,
your project will be withdrawn and you will need to reapply with a new application and a new fee.
This letter only addresses the application review and does not authorize any impacts to wetlands, waters or
protected buffers. Please be aware that any impacts requested within your application are not authorized (at
this time) by the DWQ. Please call Ms. Cyndi Karoly or Mr. Ian McMillan at 919-733-1786 if you have
any questions regarding or would like to set up a meeting to discuss this matterA
Since ly,
yndi Karoly, Supervisor
1 oversight/Express Review Permitting Unit
CBK/ym
Mr. Todd Black and Fall Creek Land Company
Page 4 of 4
February 15, 2010
cc Kevin Barnett, DWQ Asheville Regional Office
Amanda Jones, USACE Asheville Regulatory Field Office
File Copy
Clement Riddle, CEC, 718 Oakland Street, Hendersonville, NC 28791
Filename: 070168Ver2GrandviewPeaksRecreaNonalLakes(McAowell)On_Hold
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