20060180 Ver 1_Public Notice Comments_20061019

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October 18, 2006
Mr. Steve Chapin
USACE
Asheville Regulatory Field Office
151 Paton Ave, Rm 208
AsheviAe, NC 28801-5006
RE: Laurelmor Development
Watauga and Wilkes Counties, NC
Action ID: 200630172
DWQ #. 20060180 -
USFWS Log #: 42-06-241
Dear Steve:
3764 Romirger Road
Banner Elk, P1C 28604
PhlFax: 828-297946
e-mail: wccJv~skYbest.cam
EnGosed is a document containing responses to public comments received on the Laurelmor Individual
Permit Application. The document also describes plan rrwdfications made in response to comments
that have nrsuked in an appro~mate 1500 linear foot reduction in stream impacts. The applicant is
Ginn LA Laurel Creek Ltd. 1LLP, Mr. Doug Miller is the listed agent. E'nV Inc. is the consultant and
alternate contact. Please include me on the copy list of all project related correspondence.
If you have any questions regarciing this information please call me at 828-297-6946, thank you.
Sincerely,
J n C. Vlas
President, E'nV Environmental Consulting Services Inc.
Cc: Mr. Doug Miller
Mr. PaUick Warren
Mr. Tom Griffin
Mr. Ron Linville, NCWRC
Mr. Jeff Schwierjohann, NCWRC
/Ms Cyndi Karoly, NCDWQ
Mr. Daryl Lamb, NCDWQ
Mr. Bryan Tompkins, USFWS
Mr. Brian Cole, USFWS
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Report of Impact Reductions
Response to Public and Agency Comments
Action ID: 200630172
DWQ# 20060180
For:
LAURELMOR DEVELOPMENT
6050-Acre Tract
Watauga and Wilkes Counties, North Carolina
Prepared for:
Ginn-LA Laurel Creek Ltd., LLLP
389 Little Laurel Road Extension
Boone, North Carolina 28607
Prepared by:
E'nV- Environmental Consulting Services, Inc.
3764 Rominger Road
Banner Elk, North Carolina 28604
October 18, 2006
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TABLE OF CONTENTS
LOCATION MAP .........................................................................................................................................2
LOCATION ROAD MAP ............................................................................................................................3
USGS 1:100,000 TOPO SITE MAP .............................................................................................................4
USGS 1:24,000 TOPO QUADRANGLE SITE MAP .................................................................................5
2005 COLOR AERIAL SITE OVERVIEW PHOTOGRAPH .................................................................6
I. PROJECT OVERVIEW AND STATUS ...........................................................................................7
II. PROJECT MODIFICATIONS IN RESPONSE TO COMMENTS AND REEVALUATION ....8
A. GOLF COURSE NUMBER 1 ........................................................................................................... .....8
B. GOLF COURSE NUMBER 2 ................................................................................................................9
C. GENERAL PROJECT REVISIONS, APPROACH AND IMPACTS ........................................................ .....9
D. SELECTING THE LAKES AS THE LEAST ENVIRONMENTALLY DAMAGING PRACTICABLE
ALTERNATIVE ...........................................................................................................................................10
III. RESPONSE TO PUBLIC COMMENTS ....................................................................................13
A. GENERAL TOPICS OF COMMENTS ............................................................................................... ...13
B. SPECIFIC RESPONSES TO AGENCY COMMENTS ......................................................................... ...17
1. The US FWS Letter :................................................................................................................ ..18
2. The NC WRC Letter :............................................................................................................... .. 20
TABLE 1 ......................................................................................................................................................25
LAURELMOR SITE MASTER PLAN ....................................................................................................26
REVISED GOLF COURSE NUMBER 2 DESIGN (HOLES 19-36) ......................................................27
LAURELMOR IMPACT LOCATION MAP ........................................................................................ ...28
IMPACT ONE MAP .................................................................................................................................. ...29
IMPACT TWO MAP .................................................................................................................................. ...30
IMPACT THREE MAP ............................................................................................................................... ...31
IMPACT FOUR MAP ................................................................................................................................ ...32
IMPACT FIVE MAP .................................................................................................................................. ...33
LAURELMOR LAKE FRINGE PLAN VIEW ..................................................................................... ...34
GOLF COURSE SWM TYPICAL PLAN VIEW ............................................................................................ ...35
LAKE FRINGE AND SWM TYPICAL SECTIONS ........................................................................................ ...36

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Laurelmor IP Response letter 2 10/18/2006

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Laurelmor IP Response letter 3 10/18/2006

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Laurelmor IP Response letter 4 10/18/2006

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Laurelmor IP Response letter 5 10/18/2006

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Laurelmor IP Response letter 6 10/18/2006

Report of Impact Reductions and
Response to Public and Agency Comments
Project: Laurelmor
Applicant: Ginn-LA Laurel Creek Ltd., LLLP
Action ID:200630172
DWQ#: 20060180
Date: 10-13-2006
I. Proiect Overview and Status
The Laurelmor project is aloes-density residential destination resort community
situated on approximately 6,050 acres in northwestern North Carolina. Laurelmor is
located on the escarpment of the Blue Ridge physiographic region within the Elk and
Blue Ridge Townships of Watauga and Wilkes Counties. The entire site drains into
tributaries of Elk Creek within the Upper Yadkin River Watershed. All streams located
on the property are designated as Outstanding Resource Waters ("ORW") by the North
Carolina Division of Water Quality ("NCDWQ"). The site contains approximately 8.27
acres of wetlands and approximately 64 miles of jurisdictional stream channels in
numerous distinct sub-basins.
The Applicant submitted its application for an Individual Permit on ENG FORM
4345 on February 1, 2006. A site investigation, including stream and wetlands
delineation, had previously been completed on the entire site and submitted to the United
States Army Corps of Engineers ("USAGE") Asheville office on November 16, 2005.
The application was deemed complete and a Public Notice was issued on April 19, 2006.
The Public Notice deadline was May 19, 2006.
Comments were received from the North Carolina Wildlife Resources
Commission ("NCWRC") on March 14, 2006. The public comments received by the
USAGE were mailed to the Applicant on May 30, 2006. Comments were received from
the United States Fish and Wildlife Service ("USFWS") on June 12, 2006.
The NCDWQ issued a 401 Water Quality Certification (# WQC 3576) on June
12, 2006.
On June 19, 2006, at the request of the Applicant, a meeting was held between
USAGE, the NCDWQ, the NCWRC, the USFWS, the Applicant, and the Applicant's
engineering and environmental consultants. The purpose of the June 19 meeting was to
review the status of the project and application in light of the public and agency
comments received and to discuss options and ideas for further reductions in impacts
associated with the project. This response will explain modifications made to the project
and respond to comments received both in writing and verbally in the June 19 meeting.
We have organized this response as follows. First, we have explained how, in
response to agency input and our own continued evaluation, and at considerable effort
and expense, the Applicant has redesigned the project to achieve additional reductions in
impacts to waters of the United States. We believe that these additional reductions fully
meet (and arguably exceed) the Applicant's requirements to design and select the least
Laurelmor IP Response letter 7 10/18/2006

environmentally damaging practicable alternative capable of achieving the project
purpose, especially taking into consideration cost, existing technology and logistics.
Second, we have assimilated the various comments that we received and have prepared
responses to the general topics that those comments present. Finally, we have provided
more detailed responses to the comments provided by the USFWS and the NCWRC.
Please let us know if there is additional information that you would like us to present or a
particular comment to which you would like us to respond in more detail.
II. Proiect Modifications in Response to Comments and Reevaluation
As described in the initial Individual Permit application, the overall project
purpose is to construct a large, low-density residential resort golf course community.
This has not changed. The permit application submitted on February 1, 2006 shows that
the plan, from the outset, was for two 18-hole golf courses on the project. The 36-hole
configuration was and still is necessary to achieve the project purpose. As noted above,
however, and as described in more detail below, the Applicant and its planning team have
made several design changes that further reduce impacts to waters of the United States.
We are providing with this narrative a set of supporting materials that reflect the new
layout. As you will see, the result of the Applicant's changes is to reduce overall project
impacts by approximately 1,500 linear feet of stream impact and approximately 0.01
acres of wetland impact (see Table 1). The number of in-line impoundments has also
been reduced from four impoundments to only two lakes. With these changes the
impacts associated with Golf Course Number 2 have been almost eliminated while the
impacts associated with Golf Course Number 1 have been slightly increased. The
specific changes made to each course are discussed in the following paragraphs.
A. Golf Course Number 1
Several changes were made to features of Golf Course Number 1 to reduce
impacts and to facilitate the changes proposed for Course Number 2. Most significantly,
while the footprint of the large lake has not changed, the dam design for this lake has
been significantly modified (Impact Area Number 3). The original permit application
shows an earthen dam that would have been approximately 900 feet long from upstream
toe to downstream toe. The new design calls for a roller compacted concrete ("RCC")
dam that will be only approximately 200 feet long. This change required enormous
additional cost; the increase in cost for the RCC dam over the earthen dam will be on the
order of 3 to 5 million dollars. The corresponding decrease in impact will be
approximately 350 linear feet of perennial fill impact
The proposed lake at Hole Number 7 of Course Number 1 has been eliminated
(Impact Area Number 4). This change represents a reduction of about 4501inear feet of
perennial impact (150' fill and 300' flooding). The impact area proposed for the original
driving range (Impact Area Number 5) has been changed. This area will now be used for
part of the proposed clubhouse/condo core area and will require some structural fill. The
stream impacts in this area have been reduced from 435 linear to 283 linear feet; the
Laurelmor IP Response letter 8 10/18/2006

wetland impacts in this area remain unchanged. The new driving range area will involve
approximately 1351inear feet of intermittent fill (an increase of 1351inear feet).
The final change to Course Number 1 will involve the construction of an
additional lake at Hole Number 9. As described below, the proposed lake at Hole 9 is the
least environmentally damaging practicable alternative to satisfy the water demand needs
of the project. This lake will replace three previously proposed lakes (two former lakes
on Course Number 2 and the previous proposed lake at Hole Number 7), and together
with the large lake will provide enough water to meet the irrigation, fire fighting and
amenity needs of the project.
B. Golf Course Number 2
Numerous changes have been made to the design of Course Number 2 with the
result that all impacts have been eliminated with the exception of approximately 245
linear feet of intermittent stream that will be filled on Hole Number 13 and approximately
257 square feet of wetlands that will be filled at this same location. The most notable
change to Course Number 2 from the original application is a realignment of most of the
golf holes that, while resulting in a less desirable layout, still will satisfy project goals
and dramatically reduce impacts. The two lakes proposed in the previous layout have
been eliminated as well as all but one of the intermittent fills.
C. General proiect revisions, approach and impacts
Other than the impacts associated with the proposed lakes on Course 1 and the
three intermittent stream french drain impacts (two associated with fill slopes located in
the clubhouse-core area and one on Hole 13 of Course Number 2), there are no additional
permanent impacts to jurisdictional waters of the United States associated with any other
aspect of the entire development. There will be 12 golf cart crossings total for the two
golf courses. All of these will be bridged with no impacts to streams or wetlands. There
will be approximately 25 temporary impacts associated with utility crossings. There will
be approximately 39 bridged (non-impact) road crossings over streams. Of the 39 total
crossings, 8 will be associated with shared drives (accessing fewer than three building
lots) and will, therefore, have a smaller footprint, for both the drive and bridge, than a
standard subdivision road bridge. Additional efforts to avoid impacts on this project were
outlined in detail in the original permit application and include (among other things) a
more expensive sewer system installed along the roadway network (requiring frequent
pump stations rather than a gravity fed approach, and avoiding many additional crossings
and impacts), and generally putting extra effort in the form of time and resources into the
planning phase so as to avoid and minimize discharges into waters of the United States to
the maximum extent practicable. A narrative describing avoidance and minimization
efforts is at pages 64 through 71 of the February 1, 2006 Individual Permit application.
The reevaluation and redesign of the golf courses and lakes also led to additional
changes in the layout and configuration of the residential and resort aspects of the
development. The most notable change includes a shift from the 1,200 single family and
Laurelmor IP Response letter 9 10/18/2006

950 multi-family residential units to 1,500 single family and 400 multi-family units. This
change will result in a reduction of 250 residential units. The other significant change
involves the downscaling and shifting of the resort core area away from its original
location to the golf course area. This shift will, in turn, result in only one area of
concentrated development instead of two areas. The Applicant has eliminated from the
core area master plan both the resort hotel and the indoor water park. It has also
eliminated other features, including the equestrian preserve and a vineyard. The result
has been to further reduce the overall impact of the development on the property.
In sum, as a result of the redesign of Course Number 2, changes to lakes along
Course Number 1, and continued avoidance and minimization efforts, the Applicant has
reduced the overall project impacts to streams and wetlands by approximately 1,500
linear feet and 0.01 acres, respectively (see Table 1). Total stream impacts on the project
are now approximately 4,7921inear feet and total wetland impacts are now 0.17 acres.
When viewed in context, the overall project reflects an unprecedented effort to design an
appropriate, low-density development with the fewest possible impacts to waters of the
United States. Putting aside the lakes for now, the Applicant has designed two 18-hole
golf courses, 1,900 residential units and associated services and amenities (including
water and sewer systems and over 50 miles of roads) on a mountainous property with 64
miles of streams, and impacts are limited to 663 linear feet of streams and 0.04 acres of
wetlands. No further reductions to "non-lake impacts" are possible to achieve the project
purpose.
D. Selecting the lakes as the least environmentally damaging practicable
alternative
Turning to the two lakes on Course Number 1, they represent the primary impacts
associated with the project. These lakes, and the resulting impacts, are critical to
achieving the project purpose. The need for water on this project is paramount. It is
absolutely required in large quantities for fire suppression and irrigation. The Applicant
has provided correspondence from the Forest Service endorsing the construction and use
of large lakes to serve the fire fighting needs of not only this project but also the
surrounding area. The Applicant has also undertaken an extensive exploration of its
property to investigate the availability of underground water resources to provide
irrigation and fire suppression, as well as to meet the basic water needs of the residential
units and services. The Applicant has also reached agreement with surrounding property
owners and explored nearby land to try to access additional water supplies. The result
has been that the Applicant has identified water to satisfy the basic residential needs of
the project, but not those required for irrigation or large-scale fire suppression.
Importantly, the Applicant has reached the limit of its ability to supply water by
accessing the groundwater, and is also sensitive to the concerns of adjacent landowners
related to water supply, as reflected in the public comments. The Applicant therefore
believes that there is no practicable alternative to using the proposed lakes for these
purposes. The Applicant also believes that the lakes serve an important role in the
aesthetics, playability and utility of Course Number 1.
Laurelmor IP Response letter 10 10/18/2006

Given that the lakes are necessary to achieve the project purpose, the Applicant
evaluated several possible lake configurations and scenarios. Some of the guiding issues
in this effort were downstream safety issues, long term maintenance and liability issues,
engineering and design issues, and lake recharge issues. The recharge issue has emerged
as highly significant with the redesign of Course Number 2. The two lakes originally
proposed with Course Number 2 were to be used in conjunction with the larger lake on
Course Number 1 to satisfy water demand without excessively drawing down any of the
lakes. With the loss of the two Course Number 2 lakes, an additional water source is
necessary to meet the critical irrigation and fire suppression needs for the project. The
proposed lake at Hole Number 7 (Course 1) was considered but does not contain
sufficient volume or recharge to play a significant role and has subsequently been
eliminated. In the end the only viable alternative is to propose an additional lake that,
when combined with the large lake at Holes Numberl4 through 18, would meet the
overall project demand for water.
Having established that a second lake is critical to meet the water needs of the
project, the Applicant determined that proposed lake at Hole Number 9, together with the
previously proposed lake, is the least impacting alternative that accomplishes that goal.
This lake is located in the upper reaches of an unnamed tributary to Flat Branch. An on-
site investigation of this reach of stream by the NCWRC revealed that there are no fish
inhabiting this section of UT-Flat Branch. This lake will have a surface area of 3.1 acres
and a drainage area of 80 acres. As discussed below in the response to specific
comments, both this lake and the larger lake will be managed and monitored to maintain
the quality and viability of the streams and downstream ecosystems. The Applicant
believes that the new lake will have fewer impacts than other considered alternatives.
What makes the two lake scenario essential is the compatibility of characteristics
between the lakes; the larger lake having a large storage volume but slow recharge rate,
and the Hole Number 91ake having a smaller volume but relatively rapid recharge rate.
The large lake, as designed, is at elevation 2100 and will have a surface area of
approximately 17 acres, and a volume of approximately 370 acre-feet. The drainage area
of this lake is approximately 75 acres. The large lake will have a slow recharge rate and
by itself would not be capable of meeting the project's periodic peak demand of
approximately 3 acre-feet per day. However, when used in conjunction with the Hole
Number 9 lake, the large lake will provide large quantities of storage for longer duration
dry periods. The lake at Hole Number 9, as designed, is at elevation 2190 and will have a
surface area of approximately 3.1 acres, and a volume of approximately 23 acre-feet. The
drainage area of this lake is approximately 80 acres. The smaller surface area and volume
of the Hole Number 9 lake reduces evapotranspiration (ET) loss but allows for
significantly less storage than that provided by the larger Course Number 1 lake. For
example, cone-foot increase in stage, at capacity, in the Hole 9 lake will yield
approximately 3.0 acre-feet of storage while a similar unit increase in stage in the larger
lake will yield approximately 17 acre-feet of storage. This is a very significant difference
in storage given that, as noted above, peak irrigation demand will approach 3.0 acre-feet
per day. The management of these lakes will involve periodic transfers of water primarily
from the Hole Number 91ake to the larger lake. This is facilitated by the difference in
Laurelmor IP Response letter 11 10/18/2006

elevation between the lakes and other characteristics described above. These transfers
will allow excess storage captured in the Hole 9 lake during summer storms to be used to
keep the larger lake full.
The two-lake scenario will also serve to improve the ability of lake managers to
maintain a program of periodic high flow releases. Such a program will be based in part
on the results of on-going flow monitoring in both Swift Ford and Flat Branch below the
proposed dams. This program will be designed to mimic natural flow variability in
downstream reaches, including periodic bankfull flows, while continuing to meet the
other water related demands of the project.
The Applicant also considered other alternatives from a practicability standpoint.
For example, one such alternative involved replacing the original large lake with three
smaller lakes within the original footprint. This scenario, after much study, was rejected
because it did not significantly reduce impacts, did not significantly reduce cost, resulted
in a dramatic loss in storage volume, and created some difficult design problems for the
golf course.
Finally, with respect to both lakes, the Individual Permit application describes the
Applicant's consideration of alternatives, including the placement of the larger lake on
Course Number 1, the impracticability of using off-line impoundments and the avoidance
of environmental impacts associated with other alternatives. The Applicant has now
reduced the impacts associated with the larger lake by redesigning the dam at a very
significant additional cost. The resulting dam reduces overall stream impacts, and also
addresses a concern raised in the public comments about long-term dam safety. Having
determined that the in-line lakes are necessary to meet the project purpose, having
carefully considered required volumes and recharge rates, and having attempted to meet
the project needs through other approaches, the Applicant has reduced impacts to the
maximum extent feasible and has designed and selected the least environmentally
damaging practicable alternative. There is no other alternative that is capable of being
done taking into consideration cost, existing technology and logistics in light of the
overall project purpose.
In the end, the redesigned project represents a tremendous effort by the Applicant
to present an environmentally sound project that reduces the impacts to the waters of the
United States and represents its overall approach to environmental stewardship. We
would be happy to discuss any of the aspects of the Laurelmor project in more detail
and/or to answer any questions that you may have.
In the meantime, we also are providing information in response to comments
received from the public and other agencies. Some of the information provided below
duplicates the previous discussion, but it is repeated where necessary to provide a
complete answer to a comment or topic area.
Laurelmor IP Response letter 12 10/18/2006

III. Response to Public Comments
Numerous written comments were received from both the general public and
various state and federal resource agencies. Later in this document we provide specific
responses to the agency letters that were received. Before we do so, however, we include
in this section a summary of comments received, a categorization of issues of
significance, and a general response to each issue. We have provided our responses in
summary form. Again, we will be happy to provide any additional detail that you might
need.
A. General topics of comments
Our review of the written public comments revealed several broad areas of
concern relating to both direct and indirect potential impacts, as follows:
Explain why the lakes, as designed, are needed:
o We have described above the need for the lakes, and the rationale for the
proposed configuration. The original permit application explains further
how numerous proposed golf course layouts were evaluated before
selecting the two that we believed had the least impact to waters of the
United States. The application also describes the extensive avoidance and
minimization efforts that have gone into the design of this project.
o With the redesign of Course Number 2, impacts to waters of the United
States have been reduced to the maximum extent practicable. The redesign
and reevaluation process resulted in further reductions in impacts. By
eliminating the lake at Hole Number 7, and using the more expensive
RCC dams for both remaining lakes, overall project impacts have been
reduced to the maximum extent practicable while still achieving the
project purpose. The Applicant and its design team firmly believe that
further reductions would not be possible without fundamentally changing
the purpose of the project. Other than golf course related impacts, the
only other impacts to waters on the project are those temporary impacts
associated with utility crossings.
o While the overall project might not appear to be classically "water
dependent," the basic purpose of the lakes (and impacts to waters of the
United States) does depend on being located on or in the water. The lakes
will perform the critical function of providing a water supply for fire
protection and irrigation. This response and the permit application
explains our consideration of alternatives along these lines, the lack of
practicable alternatives to using in-line lakes and the resulting selection of
the two lakes to serve these purposes. The lakes will also serve as
important amenities for the golf course, and are critical to the playability
and utility of the course.
o The application and additional information provided in this document
explains the process of evaluating alternative lake sites and how the
Laurelmor IP Response letter 13 10/18/2006

currently proposed lake configuration locations is the least
environmentally damaging practicable feasible alternative.
Provide more information on the miti atg ion plan
a) The total impacts on this project have been reduced through the efforts
that we have outlined previously in this response. This reduction in
impacts will have a corresponding reduction in our expected mitigation
requirement. We propose the following quantification of required
stream and wetland mitigation based on the impacts described in this
report:
IMPACTS
i. Total stream impact on project: 4,7921inear feet
ii. Total perennial stream impact: 3,8601inear feet
iii. Total intermittent stream impact: 9321inear feet
iv. Total perennial fill impact: 2,6601inear feet
v. Total perennial inundation impact: 1,2001inear feet
vi. Total intermittent fill impact: 9321inear feet
vii. Total intermittent inundation impact: O linear feet
viii. Total Wetland impact: 7,622 square feet (0.17 acres)
MITIGATION
i. Perennial fill ratio 3:1
ii. Perennial inundation ratio 1.5:1
iii. Intermittent fill ratio 2:1
iv. Intermittent inundation ratio 1:1
v. Wetland ratio 2:1
vi. Perennial fill requirement 7,980
vii. Perennial inundation requirement 1,800
viii. Intermittent fill requirement 1,864
ix. Intermittent inundation requirement 0
x. Total stream mitigation required 11,644 linear feet
xi. Credit for previous EEP payment of $83,000 (HMR permit) at
$219. per linear foot covers 379 linear feet
xii. Final total stream mitigation requirement 11,2651inear feet
xiii. Total wetland mitigation requirement 0.34 acres of riparian
wetlands
b) Mitigation through payment into the NC EEP fund is one option. We
have been notified by EEP that they will accept payment to compensate
for all impacts requested in the original application. (6331 l.f. stream,
0.18 ac. wetlands)
Laurelmor IP Response letter 14 10/18/2006

c) We are also exploring mitigation through on-site restoration of degraded
streams. We have identified approximately 2,000 linear feet of degraded
stream channel within the project boundary. There is also ample
opportunity to restore between 0.5 and 0.75 acres of riparian wetlands.
d) We believe that we can mitigate impacts through off-site stream
restoration at the Leatherwood site, which is located approximately two
miles down Elk Creek Road. We have identified approximately 1,000
feet of existing degraded stream channel that could be used for
mitigation.
e) Finally, we are exploring mitigation through off-site stream restoration
at a farm in Wilkes County. We have identified a farm in the Fishing
Creek sub-basin that could provide the entire mitigation need. The
landowner is interested and we are working through the Wilkes County
Soil and Water District to assess the viability of this site.
At the current time mitigation of these unavoidable impacts to waters of the
United States is to be accomplished using a combination of the above approaches. Stream
restoration plans will be forwarded to agencies for review and comments as they are
developed. We look forward to working with the Corps to determine the most feasible
mitigation plan for this project.
• Explain the consideration of cumulative and secondary impacts
We believe that the direct impacts related to the Laurelmor project have been
substantially limited, and that the potential for secondary and/or cumulative impacts has
been materially reduced, as well. In addition, the unique design and project features of
the development as a whole will serve to mitigate any secondary or cumulative effects.
These features include:
o The project has been designed so that the impervious cover will be less
than 9% over the entire site
o The Applicant is imposing a conservation easement that will provide
stream buffers far in excess of requirements over the vast majority of the
64 miles of stream channels on the site, and will preserve over 2,000 acres
of open space within the development. This easement will be donated to
the Blue Ridge Rural Land Trust.
o The Applicant's ongoing and proposed additional water quality and
quantity monitoring efforts will serve to verify the effectiveness of erosion
control, storm water management, and lake release protocols adopted on
the site. The monitoring program is described in more detail in the next
sections of these comments.
o The entire road network on the site, including golf cart paths, has been
designed using bridges at stream crossings instead of pipes.
o Stormwater management measures will be incorporated into every
building site on the project, including all single family home sites.
LaurelmorlP Response letter 15 10/18/2006

• Water quality management and monitoring
o Turbidity monitoring of streams potentially affected by this project has
been on-going for the past year.
o A baseline assessment of macrobenthos is on-going for several streams
within the site.
o We have committed to long term monitoring of the stability of streams
below proposed lakes and other impact areas.
o We are in the process of developing a partnership with NCWRC to
conduct long term monitoring of trout populations, particularly in Upper
Dugger Creek and Upper South Fork Laurel Creek
o We are in the process of developing a partnership with Appalachian State
University that, if successful, will involve the funding of student
internships and research projects to monitor various water quality
parameters in streams throughout the site.
• Water q_uantit~management and monitoring
o We currently installing flow monitoring sites at several locations within
the project site
o We are in the process of developing a partnership with Appalachian State
University that, if successful, will involve the funding of student
internships and research projects to monitor various hydrologic
characteristics of streams throughout the site.
o Data collected will be used in conjunction with USGS recommendations
to determine 7Q 10 flows below impoundments.
o Data collected will be used to develop a protocol for periodic releases
from impoundments to mimic natural high flow events.
• Wildlife stewardship
o All areas of noted critical habitat for listed species have been included
within the proposed conservation area boundary.
o These include any areas that would serve as critical habitat for the Bog
Turtle and the Dwarf Flowered Heartleaf.
o The USFWS has not identified any other listed species on the project site.
o Several commenters noted the potential existence of the mountain lion
(eastern sub-species of Felis concolor). The USFWS considers this
species as extirpated in this region and does not consider this project as
having an impact on the mountain lion.
o The Applicant is developing a partnership with NC Audubon for a long
term monitoring of birds on the site. NC Audubon will be preparing a
handbook for homeowners with guidance on how to co-exist with local
bird populations.
o The Applicant is developing a partnership with NCWRC to monitor and
manage native Brook Trout populations on several streams on the site.
o The conservation easement will preserve large areas with a broad array of
habitat types and maintain migration corridors throughout the site.
Laurelmor IP Response letter 16 10/18/2006

o We have eliminated two of the proposed impoundments, and located the
two remaining proposed lakes on stream reaches devoid of fish. We will
also use cold water release structures on all dams.
• Erosion and sediment control
o From the outset of construction activities, erosion control has been a top
priority. The Applicant has committed to going well beyond the minimum
required measures in all areas of development.
o The Applicant maintains an on-site staff of over 25 who are dedicated
solely to installing and maintaining erosion control measures.
o The Applicant has standing instructions, and has given authority to
multiple individuals, to stop activities that are causing an erosion problem
or to fix a problem.
o The Applicant conducts on-going monitoring of turbidity in streams below
construction activities.
• Direct effects on surrounding~roperty owners
o Certain commenters have expressed a concern that the project will
adversely affect their water supply. The Applicant does not believe that
the Laurelmor project will adversely impact water supplies. Nevertheless,
the Applicant will pursue individual agreements with these landowners to
provide them with potable water either through a connection onto our
water supply system or drilling them another well, if their water supplies
are depleted by the activities of this project.
o Certain commenters expressed a concern about the safety of using an
earthen dam in the Dugger Creek drainage area. These dams were
eliminated with the redesign of Course Number 2, and there now are no
dams on Dugger Creek. We note that the dams on Course Number 1 will
be RCC dams, not earthen.
B. Specific Responses to A~ency Comments
Detailed comment letters were received from both the USFWS and the NCWRC.
We provide a detailed response to these comments below.
Laurelmor IP Response letter 17 10/18/2006

1. The US FWS Letter:
1. Comment regarding opposition to in-line lakes: From a very early stage in the
planning and development of this project, the Applicant has identified the need
for large quantities of irrigation and fire suppression water. The initial goal was
to locate several areas where large off-line ponds could be constructed to
accomplish this purpose. An analysis of the site revealed that, due to steep
topography and the prevalence of streams, the project site does not contain
suitable areas to construct off-line ponds that would provide sufficient irrigation
and fire suppression water. Using off-line ponds, therefore, is not a practicable
alternative in light of the needs of the project. We also note that, although certain
habitats will be modified once the ponds are constructed, the Applicant plans to
construct a littoral shelf around the perimeter of the lakes, which will provide an
overall increase in linear feet of aquatic habitat.
2. Comment regarding monitoring of streams to be impounded: We agree with this
comment and have already initiated flow and water quality monitoring programs
on the site. These programs will be expanded to include both Flat Branch and
Swift Ford Branch in the vicinity of the proposed lakes. All of the water quality
parameters mentioned (temperature, DO, particulate matter and flow), at a
minimum, will be monitored. We have calculated 7Q10 discharges using USGS
data and protocol for both streams and plan to use the field measured flow data to
develop a reservoir release program to mimic natural flows to the extent
practicable.
3. Comment regarding dam construction techniques to facilitate migration offish:
We have spent considerable time evaluating both Flat Branch and Swift Ford
Branch in the vicinity of the proposed lakes. Based on the results of our efforts
and the corroborating efforts of WRC personnel, we conclude that there are no
fish living in the vicinity of the proposed lakes.
4. Comment regarding the use of proper erosion and sedimentation control
measures: We agree with this comment.
5. Comment regarding the retention of forested buffers along all streams in the
vicinity of the proposed golf courses: We agree with the need for buffers along all
streams on the project. The applicant has in fact formally committed to placing
virtually the entire stream network on the site (over 64 miles of stream corridor)
in a permanent conservation easement to be held by the Blue Ridge Rural Land
Trust. The easement will include buffers that frequently exceed 500 feet in
overall width,. There will be some areas where buffer widths will be reduced to
30 feet, but these will be kept to a minimum. The golf courses are being designed
so that all surface runoff will be captured in storm water management Best
Management Practices ("BMPs") prior to entering stream buffer zones. In areas
that where natural vegetation is disturbed, non-fescue temporary seed will be
applied and appropriate native species will be installed as the permanent cover in
these areas. With respect to flyway areas, at present no flyways are proposed over
perennial streams that would require removal or alteration of vegetation. Flyways
are planned on certain intermittent streams, but work in these areas would involve
Laurelmor IP Response letter 18 10/18/2006

only the selective pruning or cutting of larger trees. Shrubs, saplings and
herbaceous vegetation would be left in a natural, undisturbed state.
6. Comment regarding the prohibition of equipment working in streams and leaking
equipment in the vicinity of streams or other waters: We agree with this comment.
7. Comment regarding Indirect and Cumulative Impacts: From the onset the
Applicant has strongly emphasized the avoidance of impacts to streams and
wetlands. The permit application explains how numerous possible golf course
layouts were evaluated before selecting the two that were proposed in the
application. The application also describes the numerous design decisions made
to minimize and avoid impacts throughout the project. After meeting with the
agencies, and as part of the Applicant's continued reevaluation of the project,
impacts were reduced even further, as described above. The result of these efforts
is that all permanent impacts to waters of the United States have been eliminated
except for those associated with the proposed golf courses (primarily the two
proposed lakes) plus approximately 100 linear feet of stream in one residential
area. We respect the view of the USFWS, but we believe that the impacts to the
waters of the United States have been reduced to the point where the proper focus
on impacts should be limited to the area of the lakes, dams and other small impact
areas, and not on the entire residential complex. Nevertheless, with this said, it is
important to point out several significant features of this project that greatly
reduce the likelihood for adverse impacts to the watershed or surrounding
communities, and therefore substantially reduce the risk of adverse cumulative or
secondary impacts. Laurelmor has been designed as a low density development
with a low percentage of impervious surfaces. Its proposed storm water
management, erosion control measures, and waste water treatment system all go
well beyond minimum requirements for this site. The proposed golf courses will
be designed as state of the art facilities with respect to environmental impacts, all
road and golf cart crossings on the project will be bridged instead of piped, and
over 2,000 acres of riparian land, including all streams on the site not impacted by
the proposed lakes or fills (approximately 64 miles), will be incorporated into a
permanent conservation easement. We have described above the ongoing and
proposed monitoring at the site, as well as plans to mimic natural water flows and
conditions below the dam structures. We have also described above and in our
permit application our substantial erosion control efforts. Finally, we will design
and install post-construction stormwater BMPs, in cooperation with NCDWQ,
that meet or exceed NCDWQ standards and guidelines. The BMPs will include
innovative approaches for a development of this type, including required BMPs at
single family residences and possibly BMPs to handle roadside runoff even where
not required by NCDWQ standards. In the end, given the unique nature of the
Laurelmor development and the Applicant's dedication to environmental
stewardship, we do not believe that there will be any material secondary or
cumulative impacts associated with either direct or indirect impacts at the project.
8. Comment regarding temporary impacts associated with sewer line installation:
The waste water treatment collection and disposal system proposed for Laurelmor
is designed to eliminate the need for individual septic systems on the project. In
most other developments, similarly elaborate and expensive systems are used to
Laurelmor IP Response letter 19 10/18/2006

facilitate increases in project density beyond what could be achieved using
conventional septic systems. At Laurelmor, however, project density will not be
increased because of this system; in fact, project density is being kept far below
the maximum allowable. The benefits of the proposed system will instead be to
eliminate the potential impacts from as many as 2,000 individual septic systems
on this site. Further, all effluent will be treated to reuse standards and discharged
into the ground through either spray irrigation for the golf course or drip fields in
designated areas away from any surface waters. The permit application indicates
that streams will be temporarily impacted at about 25 sites during the installation
of the waste water collection system, the impact at each site will be approximately
25 linear feet. This impact represents the minimum temporary impact necessary
after extensive efforts to avoid and minimize the effects of the system. The
Applicant's efforts included keeping the vast majority of sewer lines in road
rights-or-way or otherwise away from riparian areas. The reality of designing
such a system in steep terrain, however, results in numerous unavoidable stream
crossings. To the extent practicable, sewer lines will be kept outside of stream
buffer zones, directional boring will be used to minimize stream impacts, stream
crossings will be kept perpendicular, and the entire system will be designed to
municipal standards. The entire system will be continuously monitored.
9. Comment regarding proposed mitigation plan: We described our proposed
mitigation outline and options in the previous section of this response.
In sum, the proposed project addresses all of the concerns expressed by the
USFWS by avoiding and minimizing impacts, taking steps to avoid adverse cumulative
and secondary impacts and providing appropriate mitigation for unavoidable impacts to
waters of the United States.
2. The NC WRC Letter:
1. Comment regarding trout moratorium: We agree with this comment.
2. Comment regarding limits on land clearing during May through mid-July
to reduce impacts on nesting birds: We do not completely concur with this
comment because it would be excessively restrictive given the nature of
the proposed activity. We have initiated a partnership with Audubon NC
to begin assessing and monitoring bird population characteristics and
dynamics on the site. Part of this agreement is intended to encourage
Audubon NC to voice concerns and make recommendations regarding any
activities that may affect bird populations on the site. The applicant
agrees to work with Audubon NC to attempt to resolve all such issues.
3. Comment regarding the impoundments, as well as the stream flow issues
below the proposed impoundments: We have described above how the two
lakes provide the minimum impact necessary to achieve the project
purpose, and are the least environmentally damaging practicable
alternative. With respect to stream flow issues, we agree with the
NCWRC comment
Laurelmor IP Response letter 20 10/18/2006

4. Comment regarding storm water management: We agree with this
comment.
5. Comment regarding stream buffers: Throughout the design phase of this
project, minimum buffer widths of 30 feet have been placed around all
streams. On July 25th of this year the Applicant formally announced an
agreement with the Blue Ridge Rural Land Trust to place over 2,000 acres
of riparian land in a permanent conservation easement. This easement will
provide undisturbed natural stream buffers of well beyond the required 25
feet on either side for a large percentage of the site. In many cases the
stream buffers will exceed 500 feet. All required stream buffers, whether
in the conservation easement or not will be placed in common area. In
addition to the required buffers and conservation easement areas, all
residential lots will have a designated building envelope, and significant
removal of vegetation or land disturbance outside of this envelope will be
prohibited through the Covenants, Conditions and Restrictions ("CCRs")
of the development. This restriction will effectively add 50 to 100 feet of
additional forested width to many buffers.
6. Comment regarding wildlife corridors: We agree, see comment #5.
7. Comment regarding T&E species, particularly the bog turtle, encountered
during construction: We agree with this comment.
8. Comment regarding impacts to mines, caves, boulder fields, and rocky
outcrops: Many of these areas will be preserved within the proposed
conservation easement area. Many of these areas also occur outside of the
easement area and to the extent practicable they will be avoided. Several
of these areas will be impacted. The only mine known to exist on the site
will be inundated by the proposed larger lake, but this site has been
evaluated for species of concern several times (most recently on July 19,
2006 with Jeff Schwierjohann of the NCWRC). At no time during any of
these inspections were any species of concern found.
9. Comment regarding WRC access to monitor wildlife: We agree with this
comment and look forward to working out arrangements.
10. Comment regarding public fishing access to Dugger and Laurel Creeks:
The Applicant is in the early stages of working out an agreement with the
NCWRC to open up several areas for public access fishing.
11. Comment regarding sampling for wild trout along streams to be
inundated: Some sampling has already been performed and no fish were
found in the vicinity of either proposed lake. If additional sampling is
needed we will facilitate it.
12. Comment regarding the hiring of a site naturalist: The Applicant is
developing a relationship with the Southern Appalachian Environmental
Research and Education Center (SAEREC) at Appalachian State
University in Boone, NC. This initiative will involve the construction of a
field laboratory and on-site research center. Discussions have centered
around a range of basic and applied research that would be conducted on
the site. The center would also serve as a clearing house for water quality
and habitat data gathered on and around the site.
Laurelmor IP Response letter 21 10/18/2006

13. Comment regarding the use of bridges instead of culverts for road
crossings: The Applicant has proposed that all road and golf cart path
crossings proposed on the development will use bridges.
14. Comment regarding fills in mapped floodplains: The only mapped
floodplain areas located on the site are along Elk Creek. At the present
time there are no planned activities in these areas that would involve
grading and filling.
15. Comment regarding Blue Ridge Parkway viewshed issues: We agree with
this comment.
16. Comment regarding utility line installation in the vicinity of streams and
floodplains: To the extent practicable the design team has attempted to
minimize encroachment into stream buffer areas, including floodprone
areas. Most proposed utility lines will be located in road rights-of--way,
but there will be approximately 25 temporary stream impacts associated
with utility line crossings.
17. Comment regarding forestry operations on the site: Land disturbing
activities, including removal of trees, is strictly controlled throughout the
site. Such activities will also be controlled on individual lots through the
CCRs of the development. Each lot will have a designated building
envelope that prospective buyers will be aware of prior to purchase.
Clearing outside these specified areas will be limited, especially on steep
slopes and near buffers. No timber harvesting operations are planned or
anticipated on the site outside of areas planned for road, building or golf
course construction.
18. Comment regarding comprehensive stormwater management plan: We
agree with this comment in principle. However, it will not be possible to
limit the total site imperviousness to 6% or less and still achieve the
project purpose. The site is located in an area designated as ORW and all
development is limited to a maximum of 12% impervious cover. We have
committed to going beyond this requirement and will limit total site
imperviousness to 9%. In addition, the Applicant is working with
NCDWQ to develop a stormwater plan that will include BMPs that will
meet or exceed NCDWQ standards and guidelines. Among other things,
there will be a requirement, incorporated into the project CCRs, dictating
that each individual residential lot must have a stormwater management
plan before plans can be approved.
19. Comment regarding relocated streams: There are no plans to relocate any
streams on the site. However, as part of the mitigation plan some on-site
streams may be restored. Any such restorations will incorporate state-of-
the-art natural channel design concepts.
20. Comment regarding erosion and sedimentation controls: Currently, land
disturbing activity on the site is limited to 20 acres for roads and 20 acres
for the golf course. In addition, there is an approximate 25-person crew
that is on site continuously and that is dedicated to installing, inspecting
and maintaining erosion control measures. This crew is equipped with
three hydroseeders, and various pieces of construction equipment. Large
Laurelmor IP Response letter 22 10/18/2006

quantities of clean stone, erosion control matting, seed and mulch in stored
on site for use as needed.
21. Comment regarding permanent protection for streams, wetlands, and
buffers: See comment Number 5.
22. Comment regarding jurisdictional waters and other significant features on
lots: The Laurelmor site has been designed so that all jurisdictional waters
will be confined within dedicated conservation lands protected in
perpetuity. No individual lots will contain jurisdictional waters.
Significant habitats or geologic features will have to be addressed on a
case by case basis. To date no such areas have been identified on
individual lots.
23. Comment regarding low impact development techniques: The Laurelmor
development will be a low impact development. Numerous low impact
techniques have already been incorporated into the master planning of this
site.
24. Comment regarding bio-retention facilities: The location and design
specification of all proposed bio-retention facilities will be addressed in
the stormwater management plan to be submitted to the NCDWQ this
year.
25. Comment regarding use of native plantings: We agree to the extent
possible. The CCRs for the development will restrict the planting of non-
native species, and particularly the more invasive species. We have
obtained a list ofnon-native and exotic invasive species from NCWRC
and intend to use this list to screen landscaping plans proposed for various
areas of the development.
26. Comment regarding introduction ofnon-native species: We agree with
this comment and have initiated contact with WRC fisheries biologists in
hopes of forging a partnership to help monitor and maintain aquatic
habitats throughout the site. Also, through partnerships the Blue Ridge
Rural Land Trust, NC Audubon, ASU and other groups, we hope to be
able to properly monitor and maintain all ecosystems present on the site.
27. Comment regarding a management plan for chemical use on the golf
courses: The golf course management protocol to be used on both
proposed courses will employ a state of the art turf management and
integrated pest management program. Such a management program will
involve constant monitoring of pest populations and vegetative health
along with analysis of soil and runoff water chemistry to make sure that
both growth agents and pest control agents are applied at optimal rates and
residuals are not leaving the site. Such a program relies on an evaluation,
education, decision-making loop, in order to quickly and effectively
respond to changes in environmental factors that require changes in the
physical, biological and chemical management of the course.
28. Comment regarding removal of vegetation in steam buffers: The
Applicant's golf course design team has made extensive efforts to avoid,
to the maximum extent practicable, any flyways over stream buffers. At
the present time we believe that there are no such areas over perennial
Laurelmor IP Response letter 23 10/18/2006

streams that would require any removal of vegetation in designated buffer
zones. As noted above, flyways over intermittent streams will require the
pruning or cutting of only larger trees. Shrubs, saplings and herbaceous
vegetation will remain undisturbed.
29. Comment regarding grant opportunities for neo-tropical migratory bird
conservation efforts: We appreciate the comment.
30. Comment regarding the applicability of conditions of the previously issued
HMR permit to the Laurelmor permit: To the extent applicable, all
conditions of the HMR permit have been followed since the property was
purchased in 2005.
31. Comment regarding limiting the use of de-icing chemicals on roads within
Laurelmor: To the extent that roads can be safely maintained in the winter,
a snow and ice removal program limiting the use of de-icing chemicals
will be adopted.
Laurelmor IP Response letter 24 10/18/2006

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Table 1
Laurelmor Project: Proposed Permanent Impacts
Oct-06
Total (If) Total (If) (sfl I 1 I sq
Impact Persnnlsl ntermkbn Wetland Pennnlal Pennnlal Intermktent Intermittent WeNand Wetland
Feature Hole Slte Im cts Im acts Im acts FiIIIPi Inundated FiluPi Inundated Fill/Pi Inundated
Golf Course Dei n 31 1 0 243 257 243 257
Lake Creation 9 2 1,270 0 1,861 70 1,200 1,881
Lake Creation 14-18 3 2,490 371 4,000 2,490 371 4,000
Practice Ran e 4 0 135 0 135
Facil' Construction 5 100 183 1,464 100 183 1,484
Totals 3860 932 7,622 2,660 1,200 932 0 5,741 1 681
Total Stream Im gnear feet 4 792
Total Wetland Im acts: uare feet 7822
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Laurelmor IP Response letter 26 10/18/2006
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Laurelmor IP Response letter 28 10/18/2006

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31 10/ 18/2006

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Laurelmor IP Response letter 32 10/18/2006

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Laurelmor IP Response letter 33 10/18/2006

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Laurelmor IP Response letter 36 10/18/2006