20120053 Ver 1_More Info Received_20120530

I9, -1) ID 53
Soil & Environmental Consultants, PA
11010 Raven Ridge Road Raleigh, North Carolina 27614 Phone [phone] Fax [phone]
www SandEC com
May 29 2012
S &EC Project # 11762
To US Army Corps of Engineers
Asheville Regulatory Field Office
Attn Mr Steve Kichefski
151 Patton Avenue Room 208
Asheville North Carolina 28801
N C Division of Water Quality
WebSCaPe
Attn Ms Karen Higgins
512 N Salisbury Street 9t' floor
Raleigh NC 27603
From Soil & Environmental Consultants P A
Attn Wendell Overby
11010 Raven Ridge Road
Raleigh NC 27614
Re CAROLINA GOLF LODGE — PUBLIC NOTICE RESPONSES
INDIVIDUAL PERMIT APPLICATION
U S Army Corps of Engineers Action ID No 2012 00482
Dear Mr Kichefski and Ms Higgins
U
7MAY3aza? 1
On behalf of the owner Dillon Lakes LLC we are hereby providing additional
information in response to comments received during the Public Notice period This additional
information is an amendment to our existing Individual Permit application under review by both
the USACE (Action ID No 2012 00482) and DWQ (DWQ Project #12 0053) for the proposed
Carolina Golf Lodge project
PUBLIC NOTICE
The USACE Public Notice was issued on March 29 2012 The comment period for this Public
Noticed expired on April 12 2012 The USACE received written comments from the U S Fish
and Wildlife Services (USFWS) dated April 9 2012 N C Wildlife Resources Commission
(WRC) dated April 2012 (see attached) and an Attorney in Fact representing Myrtle M
Page 1 of 5

Carolina Golf Lodge — Individual Permit
Additional Information
May 29 2012
S &EC PA 11762
Cochrane dated April 25 2012 (see attached) Written comments were also submitted by the
North Carolina Department of Cultural Resources (DCR) and the National Marine Fisheries
Service (NMFS) The DCR and NMF had no objection or no comment on the project No other
written comments were received as of the expiration of the comment period
ADDITIONAL INFORMATION
USACE May 14, 2012 Letter (attached)
The USACE requested responses to three comment letters received either prior to or shortly
after the close of the comment period including the aforementioned USFWS WRC and
Attorney in Fact for Myrtle M Cochrane
USFWS April 9, 2012 Letter (attached)
The April 2012 letter from the USFWS is summarized by the USACE as having 2 main
concerns including 1) habitat for the federally endangered Schweinitz s sunflower
(Helianthus schweinitzii) and 2) potential direct and indirect impacts the project could have
on aquatic resources that occur on the site The USFWS provided recommendations to
minimize impacts including 1) controlling stormwater in a manner to mimic the pre
construction hydrology of the site 2) preserving and/or restoring forested riparian buffers 3)
installing and maintaining stringent sediment/erosion control 4) rrummization and careful
installation of utility lines and 5) proper operation and maintenance of equipment
1 Schweinitz s sunflower habitat
A survey for the Schweinitz s sunflower (Helianthus schweinazu) has not been
performed within project boundaries As documented in the USFWS letter the plant is
difficult to identify especially outside the flowering season of late August to October As
part of the applicant s due diligence efforts S &EC reviewed data available from the
Natural Heritage Program (NHP) on February 8 2012 regardmg the presence of
Schweinitz s sunflower on the project site Based on S &EC s review of the NHP data
no occurrence of Schweinitz s sunflower is listed within 5 miles of Carolina Golf Lodge
Suitable habitat for Helianthus schweinitzu includes field roadsides and open woodland
areas According to the USFWS the plant occurs in relatively open habitats road power
line and other maintained rights of way early successional fields forest ecotonal
margins forest cleanngs etc The USFWS letter further provides Helianthus
schweinitzu occurs on soils characterized as moist to dryish clays clay loams or sandy
clay loams Carolina Golf Lodge like most rural parcels in Mecklenburg County
contains clay based soils with field edges forest clearings and rights of way Based on
the generic habitat requirements flowering season period and lack of known occurrences
within 5 miles of the site we believe that a survey for Helianthus schwinitzu should not
be required
2 Direct and Indirect Impacts to Aquatic Resources
The applicant has made every attempt to minimize impacts to wetland streams and open
waters on site while still maintaining a viable project and meeting the project purpose as
Page 2 of 5

Carolina Golf Lodge — Individual Permit
Additional Information
May 29 2012
S &EC PA 11762
described in the original application package Alternative project designs were evaluated
to determine which alternative accomplishes the project purpose with the least adverse
impact on the aquatic ecosystem No stream impacts are proposed for the project and
impacted features are man made in origin (e g pond and drained pond wetlands)
Furthermore the applicant will mitigate for permanent losses to wetlands via payment to
the NC Ecosystem Enhancement Program (EEP)
1 Stormwater Management
Carolina Golf Lodge will require a grading perrrut for construction A
stormwater management plan is also required by local and state agencies with the
City of Charlotte to review and approve finalized plans The proposed
stormwater plan will be designed per current DWQ Best Management Practices
Manual to remove 85% Total Suspended Solids (TSS) for impervious areas
Operation and maintenance agreements will be required for SMP approval A
final SMP will be provided to NC DWQ prior to commencement of approved
impacts to jurisdictional waters We do not anticipate any negative downstream
water quality or flooding impacts associated with stormwater runoff from the site
and in fact believe this project has the potential to improve the current
downstream water quality with the installation of appropriate stormwater BMPs
In addition to the water quality aspects the stormwater pond will detain
stormwater so that the post development peak flows for the 10 and 25 year storm
mimics the pre development conditions In other words the post development
hydrology will mimic the pre development conditions
2 Riparian Buffers
If the latest Exhibit A - Preferred Alternative (attached) is accepted by the
USACE then the applicant will maintain 188 acres of wetlands 1 030 feet of
streams and 0 33 acres of open waters on site protected in a declaration of
conservation Additionally there are no plans by the applicant to impact wetland
#1 ( 111 acres) and Pond C (5 08 acres) In addition to conserving jurisdictional
features the configuration of Carolina Golf Lodge will result in undisturbed areas
(e g riparian buffers) adjacent to streams #1 and #2
3 Erosion and Sediment Control
In order to obtain a grading permit for construction Carolina Golf Lodge will
follow erosion and sediment control plans required by the City of Charlotte under
the North Carolina Sediment Control Law These plans will incorporate
requirements set by the City of Charlotte regarding use and installation of silt
fence use of skimmers to dewater sediment ponds from the top and the timely
establishment of vegetation on disturbed areas The project will obtain an
approved erosion control plan from the City and maintain the plan throughout
construction The City of Charlotte is an NC DWQ locally delegated authority
for erosion and sediment control approval
Page 3 of 5

Carolina Golf Lodge — Individual Pernut May 29 2012
Additional Information S &EC PA 11762
4 Installation of Utility Lines
The applicant will take all precautions to keep utility lines outside jurisdictional
Waters and riparian buffers
5 Equipment Operation and Maintenance
Fueling operations will be conducted outside of the npanan/conservation areas
and away from Waters Equipment will be kept out of streams and Waters
WRC April 9, 2012 Letter (attached)
The WRC provided four recommendations to the USACE
1 Maintaining native forested buffers along streams and wetlands
If the latest Exhibit A — Preferred Alternative (attached) is accepted by the USACE then
the applicant will maintain 188 acres of wetlands 1 030 feet of streams and 0 33 acres of
open waters on site protected in a declaration of conservation Additionally there are no
plans by the applicant to impact wetland #1 ( 111 acres) and Pond C (5 08 acres) In addition
to conserving jurisdictional features the configuration of Carolina Golf Lodge will result in
undisturbed areas (e g riparian buffers) adjacent to streams #1 and #2
2 Limiting Fertilizers and Pesticides / Stormwater and Irrigation Runoff
The Carolina Golf Lodge will use fertilizers on the greens and fairways to establish and
maintain course grass Fertilizers and pesticides will not be used in riparian buffers and
Waters Drains underlying course greens will not be discharged directly to Waters
Algae blooms will be controlled through low phosphorus inputs of not more than 1
pound annually applied and slow release low soluble fertilizers to minimize nutrient
runoff to surface waters
3 Planting Native Buffers Around Stormwater or Golf Course Ponds
Where practical the applicant will plant native vegetation around stormwater facilities
and on site ponds Stormwater management plans will be designed to meet or exceed
current DWQ BMP requirements
4 Sediment and Erosion Control Measures
In order to obtain a gradmg permit for construction Carolma Golf Lodge will follow
erosion and sediment control plans required by the City of Charlotte under the North
Carolina Sediment Control Law These plans will incorporate requirements set by the
City of Charlotte regarding use and installation of silt fence use of skimmers to dewater
sediment ponds from the top and the timely establishment of vegetation on disturbed
areas The project will obtain an approved erosion control plan from the City and
maintain the plan through out construction The City of Charlotte is an NC DWQ locally
delegated authority for erosion and sediment control approval
Page 4 of 5

Carolina Golf Lodge — Individual Perirut May 29 2012
Additional Information S &EC PA 11762
Myrtle M Cochrane April 25, 2012 Letter (attached)
A letter from Mrs Myrtle M Cochrane s Attorney in Fact was received by the USACE on
April 30 2012 after the public notice comment period The letter expressed Mrs Cochrane s
concern over the potential impact of Carolina Golf Lodge on drainage and runoff affecting
her property In addition the letter expressed concern over any negative affects Carolina
Golf Lodge may have regarding Mrs Cochrane s ability to sell her property
Mrs Cochrane s property is located at the northeast corner of the Carolina Golf Lodge (see
attached Mecklenburg County GIS map) Mrs Cochrane s property occurs uphill and more
importantly upstream of the subject property The stream on Mrs Cochrane s property flows
into the largest open water (Pond C) on Carolina Golf Lodge No changes of pre
development water levels to Pond C are expected for the proposed development As a result
drainage and runoff will not be affected on Mrs Cochrane s property It is our opinion that
construction of a world class golf training facility will not negatively affect the ability of Mrs
Cochrane to sell her property
CONCLUSION
It is our understanding that this additional information will provide you all of the information
required for you to continue the review of this permit application Please contact us if you require
any information beyond what has been provided in this response We appreciate your review and
comments
Sincerely
Soil & Environmental Consultants PA
W 014, W
Wendell Overby
NC Licensed Soil S entist
NC Registered Forester
Attachments Exhibit A Preferred Alternative" Site Plan
USACE May 14, 2012 Letter
USFWS April 9, 2012 Letter
WRC April 9, 2012 Letter
Myrtle M Cochrane April 25, 2012 Letter
Mecklenburg County `Polaris' GIS Map
Page 5 of 5

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May 14 2012
Regulatory Division
Action ID SAW 2012 00482
Mr Jonathan B Jarrett
Dillon Lakes LLC
817 Romany Road
Charlotte North Carolina 28203
Dear Mr Jarrett
Reference is made to the application of March 14 2012 for individual Department of the
Array (DA) permit authorization to permanently impact impact 0 38 acres wetland and 2 44 acre
of open water associated with the construction of a golf training facility in Charlotte,
North Carolina.
After review of your proposal, the United States Department of Interior Fish and Wildlife
Services ( USFWS) submitted comments by letter dated April 9 2012 A copy of this letter is
enclosed for your consideration and response Specifically the USFWS stated the following
1 Based on project location and pictures obtained from the Mecklenburg County GIS
websnte there appears to be suitable habitat for the federally endangered Schweinntz s
sunflower (Hehanthus sehweznztzzz) Unless the area has been specifically surveyed for
this species, a survey should be conducted to ensure that tins species is not
inadvertently lost
2 They also expressed concern about any potential direct and indirect impacts that tlus
project could have on aquatic resources that occur on the site Therefore they
recommend mmnrmzatzon of impacts through 1) controlling stormwater in a manner to
mimic the pre construction hydrology of the site 2) preserving and/or restoring
forested riparian buffers 3) installing and maintaining stringent sediment/erosion
control 4) mi unuzation and careful installation of utility Imes 5) proper operation and
maintenance of equipment
Written comments were also received from the North Carolina Wildlife Resources
Commission (WRC) on April 2012 A copy of this correspondence is enclosed for your
consideration and response Specifically the WRC offered recommendations should the permit
be issued
1 Maintaining native forested buffers along streams and wetlands

- 2 -
2 Limiting fertilizers and pesticides as well as managing the stormwater and irrigation
runoff
3 Planting native buffers around stormwater or golf course ponds
4 Sediment and erosion control measures should be installed prior to any land clearing or
construction These measures should be routinely inspected and properly maintained
We received a comment letter from an Attorney in fact representing Myrtle M Cochrane
an adjacent/area property owner in response to the PN advertising this project in this letter
which was received after the comment period deadline concern was expressed over the
development and its impact on the drainage and runoff affecting Mrs Cochrane's property
Written comments stating no objection or no comment on the project were received from
the North Carolina Department of Cultural Resources and the National Marine Fisheries Service
While no response is necessary their correspondence is attached for your records
Your response to the comments identified above must be given full consideration before we
can make a final decision on your application We need your information to address the
concerns /issues raised over the proposed project You may submit additional information, revise
your plans to help resolve the issues rebut the issues made or request a decision based on the
existing record We must hear from you within 30 days otherwise your application will be
withdrawn If you have questions or comments please contact me at my Asheville Regulatory
Field Office address telephone [phone] ext 234
Sincerely
FILENAME SAW 2012 00482 PN Comment Ltr Final docx /nw
CESAW RG A/Kichefski/s
MAIL
CESAW RG A/file
Steve Kichefski
Regulatory Specialist
Asheville Regulatory Field Office
Enclosure
Copies Furnished (without enclosure)
Ms Karen Higgins
North Carolina Division of Water Quality
Wetlands Buffers Stormwater Compliance
and Permitting Unit
1650 Mail Service Center
Raleigh, North Carolina 27699 1650

- 3 -
Mr Brian Cole
Asheville Field Office
U S Fish and Wildlife Service
160 Zillicoa Street
Asheville North Carolina 28801
Jeffrey Garnett
Wetlands and Marine Regulatory Section
Water Protection Div Region 1V
U S Environmental Protection Agency
61 Forsyth Street SW
Atlanta, Georgia 30303
Ms Shan Bryant
North Carolina Wildlife Resource Commission
Piedmont Region Coordinator
Habitat Conservation Program
1721 Mail Service Center
Raleigh, North Carolina 27699 1721
Mr Wendell Overby
Soil & Environmental Consultants PA
11010 Raven Ridge Road
Raleigh, North Carolina 27614

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa Street
Asheville North C-irohna28801
April 9 2012
Mr Steve Kichefski
US Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue Room 208
Asheville North Carolina 28801
Dear Mr Kichefski
This is the report of the U S Fish and Wildhfe Service and the Department of the Interior on the
U S Army Corps of Engineers (Corps) public notice (PN)(SAW -2012 00482) of an application
for an individual permit submitted by Mr Jonathan B Jarrett of Dillon Lakes LLC represented
by Mr Wendell Overby of Soil & Environmental Consultants Information for this report is
based on a review of the public notice issued by the Corps This report is submitted in
accordance with the provisions of the Fish and Wildhfe Coordination Act as amended
(16 U S C 661 667e) the National Environmental Policy Act (42 U S C §4321 et seq ), the
Clean Water Act (33 U S C § 1251 et seq ) and section 7 of the Endangered Species Act of
1973 as amended (16 U S C 1531 1543) (Act)
Project Description According to the information provided, the purpose of the project is to
construct a comprehensive and integrated golf training facility The project consists of
constructing a clubhouse two cottages putting greens parking area storm water facilities and
associated infrastructure The design of the golf tranung facility will include short game and
dnvmg ranges areas along with (3) par three holes Aquatic impacts to wetlands and an open
water /pond are proposed for the project Total aquatic impacts associated with the project
include 0 38 acre of wetland and 2 44 acres of open water No stream impacts are proposed for
this project
Federally Listed Species — Based on the project location and pictures obtained from the
Mecklenburg County GIS web site there appears to be suitable habitat for the federally
endangered Schwemitz s sunflower (Helianthus schweinatzit) This plant has been found in close
proximity to the project site The project site contains a field, roadsides and open woodland
areas all of which are suitable habitat for Schweinitz's sunflower Schweinrtz s sunflower
occurs in relatively open habitats road, power line, and other maintained rights of way early
successional fields forest ecotonal margins, forest clearings etc The species thrives in full sun

but also grows in the light shade of open stands of oak pine hickory Schweuntz s sunflower
generally occurs on soils characterized as moist to dryish clays clay loams or sandy clay loams
that often have high gravel content The PN did not indicate whether surveys have been
conducted for this plant species within the project impact area. Unless an area has been
specifically surveyed for this species a survey should be conducted to ensure that this species is
not inadvertently lost Schweuutz s sunflower is difficult to identify at any time, but even more
so outside the flowering season of late August to October so we recommend that surveys for this
species be conducted during this period In accordance with the Act it is the responsibility of
the appropriate federal agency or its designated representative to review its activities or programs
and to identify any such activities or programs that may affect endangered or threatened species
or their habitats If it is determined that the proposed activity may adversely affect any species
federally listed as endangered or threatened, formal consultation with this office must be
initiated
Fish and Wildlife Resources — We are concerned about any potential direct and indirect impacts
that this project could have on aquatic resources that occur on the site It is unportant that you
minimize or avoid impacts to the aquatic resources located on the property According to the
404 (b)(1) guidelines no discharge or fill material shall be permitted in streams or wetlands if
there is a practicable alternative to the proposed discharge that would have less adverse impacts
on the aquatic ecosystem (40 CFR 230 10), therefore we recommend the following measures to
help minimize project impacts
Control storm water in a manner that will mimic the pre construction
hydrology of the project site We recommend the use of grassed swales in
place of curb and gutter and on site storm water management (i e
bioretentmon areas) that will result in no net change in the hydrology of the
watershed All storm water outlets should drain through a vegetated upland
area prior to reaching any stream or wetland area Sufficient retention designs
should be implemented to allow for the slow discharge of storm water
attenuating the potential adverse effects of storm water surges thermal spikes
and sediment, nutrient and chemical discharges
2 Preserve and/or restore forested riparian buffers Given the close proximity of
this project to aquatic resources and the increase of impervious surfaces that
will occur as a result of the development we are concerned about the loss and
lack of riparian buffers Forested riparian buffers, a minimum of 100 feet
wide along perennial streams and 50 feet wide along intermittent streams
should be created and/or maintained along all aquatic areas Riparian buffers
provide travel corridors and habitat for wildlife displaced by development In
addition, riparian buffers protect water quality by stabilizing stream banks
filtering storm water runoff and providing habitat for aquatic and fisheries
resources
E

3 Install and maintain stringent measures to control erosion and sediment in
order to prevent unnecessary impacts to aquatic resources within and
downstream of the project site Disturbed areas should be reseeded with
native annual small grams that are appropriate for the season Fescue based
mixtures should be avoided If riparian vegetation is removed during
construction activities along streams we strongly recommend that native
riparian vegetation (including sedges grasses and rushes as well as native
woody species) in lieu of traditional hard treatments such as nprap, be used to
stabilize the stream banks and to restore the riparian vegetation
Biodegradable erosion control matting should be used in conjunction with
appropriate seeding on disturbed soils in riparian areas Matting should be
secured in place with staples stakes or live stakes of native trees (whenever
possible) Perimeter erosion control devices should be installed prior to any
on the ground activities Frequent maintenance of these devices is critical to
their proper function in order to minimize sediment discharge from the project
site Frequent maintenance of these devices is critical to their proper function
in order to minimize sediment discharge from the project site Perimeter
erosion control devices should be installed prior to any on the ground
activities
4 Install utility lines (i e , sewer gas water) outside the above recommended
buffer widths All utility crossings should be kept to a muumum and all utility
infrastructure should be kept out of riparian buffer areas The directional bore
stream crossing method (installation of utilities beneath the riverbed avoiding
impacts to the stream and buffer) should be used for utility crossings
Manholes or similar access structures should not be allowed within buffer
areas Stream crossings should be near perpendicular to stream flow and
should be monitored at least every 3 months for maintenance needs during the
first 24 months of the project and annually thereafter Sewer lines associated
with crossing areas should be maintained and operated at all tunes to prevent
discharges to land or surface waters In circumstances where minimum
setbacks cannot be attained sewer lines shall be constructed of ductile iron or a
substance of equal durability
S Keep equipment out of streams by operating from the banks in a fashion that
minimizes disturbance to woody vegetation Equipment should be inspected
daily and should be maintained to prevent the contamination of surface waters
from leaking fuels lubricants hydraulic fluids or other toxic materials All
fuels lubricants and other toxic materials should be stored outside the riparian
management area of the stream, in a location where the material can be
contained Equipment should be checked for leaks of hydraulic fluids, cooling
system liquids and fuel and should be cleaned before fording any stream
Also all fueling operations should be accomplished outside the riparian
management area.

We appreciate the opportunity to provide these comments If we can be of assistance or if you
have any questions please do not hesitate to contact Mr Bryan Tompkins of our staff at
828/258 3939 Ext 240 In any future correspondence concerning this project, please reference
our Log Number 4 2 12 132
Sincerely
original signed
Brian P Cole
Field Supervisor
4

Ks�zl North Carolina Wildlife Resources Commission
Gordon Myers Executive Director
MEMORANDUM
TO Steve Kichefski, Asheville Regulatory Field Office
U S Army Corps of Engineers
FROM Shan L Bryant Piedmont Region Coordinator
Habitat Conservation Program
DATE 9 April 2012
SUBJECT Public Notice for Dillon Lakes LLC for Construction of a Carolina Golf Lodge
Charlotte Mecklenburg County North Carolina Corps Action ID # SAW 2012 00482
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document Our comments are provided in accordance with provisions of the Clean Water Act of
1977 (as amended) Fish and Wildlife Coordination Act (48 Stat 401 as amended 16 U S C 661 667e)
and North Carolina General Statutes (G S 113 131 et seq )
The applicant proposes to permanently impact 0 38 acres of wetlands and 2 44 acres of open
water to construct a golf training facility including a clubhouse two cottages putting green parking area
stormwater facilities and other associated infrastructure The purpose of the project is to construct a
comprehensive and integrated golf training facility Mitigation for the project includes payment into the
N C Ecosystem Enhancement Program and preservation of the remainin g jurisdictional features
including 0 188 acres of wetlands 0 33 acres of open water and 1 030 Imear feet of stream channel by
declaration of conservation
The project site drams to an unnamed tributary to Irwins Creek in the Catawba River Basin.
According to the Public Notice the proposed wetland impacts would occur to features that formed after
two ponds were drained in 2003 and the open water impacts would occur to a man made feature No
stream impacts are proposed for the project
Should the permit be issued, we offer the following recommendations to min,mi e impacts to
aquatic and terrestrial wildlife resources
1 Maintain a minimum 100 foot undisturbed native forested buffer along each side of perennial
streams and 50 foot undisturbed, native forested buffer along each side of intermittent streams and
wetlands Riparian buffers provide habitat areas for aquatic and terrestrial wildlife species and travel
corridors for terrestrial wildlife In addition riparian buffers protect water quality by stabilizing
stream banks and filtering stormwater runoff
MaiItng Address Division of Inland Fisheries 1721 Mail Service Center Raleigh NC 27699 1721
Telephone [phone] Fax [phone]

Page 2
9 April 2012
Carolina Golf Lodge
Corps Action ID No SAW 2012 00482
2 Limit application of fertilizers and pesticides within riparian buffers and use non chemical control
measures wherever possible Stormwater and irrigation runoff from greens and tees should be
retained and not be allowed to discharge directly to surface waters Constructing wetlands near
greens and tees may be helpful in treating runoff pollutants such as fertilizers and pesticides
3 Where feasible native trees and shrubs should be planted around stormwater or golf course ponds to
provide avian and terrestrial habitat and to reduce exposure of the water surface to sunlight These
should provide habitat benefits that could offset those functions lost by development partially restore
aquatic habitats reduce exposure of the water surface to sunlight thereby minimizing thermal
pollution and provide essential summer and winter habitats
4 Sediment and erosion control measures should be installed prior to any land clearing or construction
These measures should be routinely inspected and properly maintained Excessive silt and sediment
loads can have numerous detrimental effects on aquatic resources including destruction of spawning
habitat suffocation of eggs and clogging of gills of aquatic species
Thank you for the opportunity to comment on tins project If we can provide further assistance
please contact our office at [phone] or share bUant ,ncwnldlnfe org
ec Alan Johnson, NCDWQ

April 25 2012
Steve Kichefski Aop o 0 2012
Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue Room 208
Asheville NC 28801 5006
Mr Kichefski
I have lust received the Public Notice (Action# SAW 2012 00482) regarding the
application from Mr Jonathan B Jarrett for construction of a golf training facility in
Charlotte N C The issue date was March 29 the deadline was April 12 and I received it
April 9 consequently I have not had adequate time to respond and this response is late
I am the Attorney in Fact for Mrs W E Cochrane owner the property which adjoins
the property in question at its northeast corner We would like to express our concern over
the development and its impact on the drainage and runoff affecting Mrs Cochrane s
property The property is currently on the market and she cannot afford to be adversely
affected by the project.
Has a hearing been requested regarding the development and if so I would like the
details so I might attend If there are any additional findings or impact statements I would
like copies of those
I await your reply
Cyrus S Hapgood
Attorney in Fact for Myrtle M Cochrane

Mecklenburg County NC POLARIS Page 1 of 1
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POLARIS
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Date Printed. Mon May 211547-55 EDT 2012
Cochrane Property,
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,sources should be consulted for verficatron Mecldenburg Courtly and is mapprng contractors assume no legal responsib�Gty for the mformahon
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Soil & Environmental Consultants, PA
11010 Raven Ridge Road Raleigh, North Carolina 27614 Phone [phone] Fax [phone]
www SandEC coin
May 29 2012
S &EC Project # 11762
To US Army Corps of Engineers
Asheville Regulatory Field Office
Attn Mr Steve Kichefski
151 Patton Avenue Room 208
Asheville North Carolina 28801
N C Division of Water Quality
WebSCaPe
Attn Ms Karen Higgins
512 N Salisbury Street 9a' floor
Raleigh NC 27603
From Soil & Environmental Consultants P A
Attn Wendell Overby
11010 Raven Ridge Road
Raleigh NC 27614
Re CAROLINA GOLF LODGE — PUBLIC NOTICE RESPONSES
INDIVIDUAL PERMIT APPLICATION
U S Army Corps of Engineers Action ID No 2012 00482
Dear Mr Kichefski and Ms Higgins
On behalf of the owner Dillon Lakes LLC we are hereby providing additional
information in response to comments received during the Public Notice period This additional
information is an amendment to our existing Individual Permit application under review by both
the USACE (Action ID No 2012 00482) and DWQ (DWQ Project #12 0053) for the proposed
Carolina Golf Lodge project
PUBLIC NOTICE
The USACE Public Notice was issued on March 29 2012 The comment period for this Public
Noticed expired on Apnl 12 2012 The USACE received written comments from the U S Fish
and Wildlife Services (USFWS) dated April 2012 N C Wildlife Resources Commission
(WRC) dated April 9 2012 (see attached) and an Attorney in Fact representing Myrtle M
Page 1 of 5

Carolina Golf Lodge — Individual Permit
Additional Information
May 29 2012
S &EC PA 11762
Cochrane dated April 25 2012 (see attached) Written comments were also submitted by the
North Carolina Department of Cultural Resources (DCR) and the National Marine Fisheries
Service (NMFS) The DCR and NMF had no objection or no comment on the project No other
written comments were received as of the expiration of the comment period
ADDITIONAL INFORMATION
USACE May 14, 2012 Letter (attached)
The USACE requested responses to three comment letters received either prior to or shortly
after the close of the comment period including the aforementioned USFWS WRC and
Attorney in Fact for Myrtle M Cochrane
USFWS Apn19, 2012 Letter (attached)
The April 2012 letter from the USFWS is summarized by the USACE as having 2 main
concerns including 1) habitat for the federally endangered Schweinitz s sunflower
(Helianthus schweinitzn) and 2) potential direct and indirect impacts the project could have
on aquatic resources that occur on the site The USFWS provided recommendations to
minimize impacts including 1) controlling stormwater in a manner to miinic the pre
construction hydrology of the site 2) preserving and/or restoring forested riparian buffers 3)
installing and maintaining stringent sediment/erosion control 4) mimmization and careful
installation of utility lines and 5) proper operation and maintenance of equipment
1 Schweinitz s sunflower habitat
A survey for the Schweinitz s sunflower (Helianthus schweinitzii) has not been
performed within project boundaries As documented in the USFWS letter the plant is
difficult to identify especially outside the flowering season of late August to October As
part of the applicant s due diligence efforts S &EC reviewed data available from the
Natural Hentage Program (NHP) on February 8 2012 regarding the presence of
Schweinitz s sunflower on the project site Based on S &EC s review of the NHP data
no occurrence of Schweinitz s sunflower is listed within 5 miles of Carolina Golf Lodge
Suitable habitat for Helianthus schweinitzit includes field roadsides and open woodland
areas According to the USFWS the plant occurs in relatively open habitats road power
line and other maintained nghts of way early successional fields forest ecotonal
margins forest clearings etc The USFWS letter further provides Helianthus
schwetnitzit occurs on soils characterized as moist to dryish clays clay loams or sandy
clay loams Carolina Golf Lodge like most rural parcels in Mecklenburg County
contains clay based soils with field edges forest clearings and nghts of way Based on
the generic habitat requirements flowering season period and lack of known occurrences
within 5 miles of the site we believe that a survey for Helianthus schwinttzit should not
be required
2 Direct and Indirect Impacts to Aquatic Resources
The applicant has made every attempt to minimize impacts to wetland streams and open
waters on site while still maintaining a viable project and meeting the project purpose as
Page 2 of 5

Carolina Golf Lodge — Individual Permit
Additional Information
May 29 2012
S &EC PA 11762
described in the original application package Alternative project designs were evaluated
to determine which alternative accomplishes the project purpose with the least adverse
impact on the aquatic ecosystem No stream impacts are proposed for the project and
impacted features are man made in ongm (e g pond and drained pond wetlands)
Furthermore the applicant will mitigate for permanent losses to wetlands via payment to
the NC Ecosystem Enhancement Program (EEP)
1 Stormwater Management
Carolina Golf Lodge will require a grading permit for construction A
stormwater management plan is also required by local and state agencies with the
City of Charlotte to review and approve finalized plans The proposed
stormwater plan will be designed per current DWQ Best Management Practices
Manual to remove 85% Total Suspended Solids (TSS) for impervious areas
Operation and maintenance agreements will be required for SMP approval A
final SMP will be provided to NC DWQ prior to commencement of approved
impacts to jurisdictional waters We do not anticipate any negative downstream
water quality or flooding impacts associated with stormwater runoff from the site
and in fact believe this project has the potential to improve the current
downstream water quality with the installation of appropnate stormwater BMPs
In addition to the water quality aspects the stormwater pond will detain
stormwater so that the post development peak flows for the 10 and 25 year storm
mimics the pre development conditions In other words the post development
hydrology will mumc the pre development conditions
2 Riparian Buffers
If the latest Exhibit A — Preferred Alternative (attached) is accepted by the
USACE then the applicant will maintain 188 acres of wetlands 1 030 feet of
streams and 0 33 acres of open waters on site protected in a declaration of
conservation Additionally there are no plans by the applicant to impact wetland
#1 ( 111 acres) and Pond C (5 08 acres) In addition to conserving jurisdictional
features the configuration of Carolina Golf Lodge will result in undisturbed areas
(e g riparian buffers) adjacent to streams #1 and #2
3 Erosion and Sediment Control
In order to obtain a grading permit for construction Carolina Golf Lodge will
follow erosion and sediment control plans required by the City of Charlotte under
the North Carolina Sediment Control Law These plans will incorporate
requirements set by the City of Charlotte regarding use and installation of silt
fence use of skimmers to dewater sediment ponds from the top and the timely
establishment of vegetation on disturbed areas The project will obtain an
approved erosion control plan from the City and maintain the plan throughout
construction The City of Charlotte is an NC DWQ locally delegated authority
for erosion and sediment control approval
Page 3 of 5

Carolina Golf Lodge — Individual Permit
Additional Information
4 Installation of Utility Lines
May 29 2012
S &EC PA 11762
The applicant will take all precautions to keep utility lines outside jurisdictional
Waters and riparian buffers
5 Equipment Operation and Maintenance
Fueling operations will be conducted outside of the npanan/conservation areas
and away from Waters Equipment will be kept out of streams and Waters
WRC April 9, 2012 Letter (attached)
The WRC provided four recommendations to the USACE
1 Maintaining native forested buffers along streams and wetlands
If the latest Exhibit A — Preferred Alternative (attached) is accepted by the USACE then
the applicant will maintain 188 acres of wetlands 1 030 feet of streams and 0 33 acres of
open waters on site protected in a declaration of conservation Additionally there are no
plans by the applicant to impact wetland #1 ( 111 acres) and Pond C (5 08 acres) In addition
to conserving jurisdictional features the configuration of Carolina Golf Lodge will result in
undisturbed areas (e g riparian buffers) adjacent to streams #1 and #2
2 Limiting Fertilizers and Pesticides / Stormwater and Irrigation Runoff
The Carolina Golf Lodge will use fertilizers on the greens and fairways to establish and
maintain course grass Fertilizers and pesticides will not be used in riparian buffers and
Waters Drains underlying course greens will not be discharged directly to Waters
Algae blooms will be controlled through low phosphorus inputs of not more than 1
pound annually applied and slow release low soluble fertilizers to minimize nutrient
runoff to surface waters
3 Planting Native Buffers Around Stormwater or Golf Course Ponds
Where practical the applicant will plant native vegetation around stormwater facilities
and on site ponds Stormwater management plans will be designed to meet or exceed
current DWQ BMP requirements
4 Sediment and Erosion Control Measures
In order to obtain a grading permit for construction Carolina Golf Lodge will follow
erosion and sediment control plans required by the City of Charlotte under the North
Carolina Sediment Control Law These plans will incorporate requirements set by the
City of Charlotte regarding use and installation of silt fence use of skimmers to dewater
sediment ponds from the top and the timely establishment of vegetation on disturbed
areas The project will obtain an approved erosion control plan from the City and
maintain the plan through out construction The City of Charlotte is an NC DWQ locally
delegated authority for erosion and sediment control approval
Page 4 of 5

Carolina Golf Lodge — Individual Permit May 29 2012
Additional Information S &EC PA 11762
Myrtle M Cochrane April 25, 2012 Letter (attached)
A letter from Mrs Myrtle M Cochrane s Attorney in Fact was received by the USACE on
April 30 2012 after the public notice comment period The letter expressed Mrs Cochrane s
concern over the potential impact of Carolina Golf Lodge on drainage and runoff affecting
her property In addition the letter expressed concern over any negative affects Carolina
Golf Lodge may have regarding Mrs Cochrane s ability to sell her property
Mrs Cochrane s property is located at the northeast corner of the Carolina Golf Lodge (see
attached Mecklenburg County GIS map) Mrs Cochrane s property occurs uphill and more
importantly upstream of the subject property The stream on Mrs Cochrane s property flows
into the largest open water (Pond C) on Carolina Golf Lodge No changes of pre
development water levels to Pond C are expected for the proposed development As a result
drainage and runoff will not be affected on Mrs Cochrane s property It is our opinion that
construction of a world class golf training facility will not negatively affect the ability of Mrs
Cochrane to sell her property
CONCLUSION
It is our understanding that this additional information will provide you all of the information
required for you to continue the review of this permit application Please contact us if you require
any information beyond what has been provided in this response We appreciate your review and
comments
Sincerely
Soil & Environmental Consultants PA
W 0,vW
Wendell Overby
NC Licensed Soil S entist
NC Registered Forester
Attachments Eadubit A Preferred Alternative" Site Plan
USACE May 14, 2012 Letter
USFWS April 9, 2012 Letter
WRC April 9, 2012 Letter
Myrtle M Cochrane April 25, 2012 Letter
Mecklenburg County `Polaris' GIS Map
Page 5 of 5

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EXHIBIT A
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PREFERRED ALTERNATIVE
32612

May 14 2012
Regulatory Division
Action ID SAW 2012 00482
Mr Jonathan B Jarrett
Dillon Lakes LLC
817 Romany Road
Charlotte North Carolina 28203
Dear Mr Jarrett
Reference is made to the application of March 14 2012 for individual Department of the
Army (DA) permit authorization to permanently impact impact 0 38 acres wetland and 2 44 acre
of open water associated with the construction of a golf trasmng facility in Charlotte
North Carolina.
After review of your proposal the United States Department of Interior Fish and Wildlife
Services ( USFWS) submitted comments by letter dated April 9 2012 A copy of this letter is
enclosed for your consideration and response Specifically the USFWS stated the following
1 Based on project location and pictures obtained from the Mecklenburg County GIS
websnte there appears to be suitable habitat for the federally endangered Schweinntz s
sunflower (Hehanthus schweinatzzi) Unless the area has been specifically surveyed for
this species a survey should be conducted to ensure that this species is not
inadvertently lost
2 They also expressed concern about any potential direct and indirect impacts that this
project could have on aquatic resources that occur on the site Therefore they
recommend minimization of impacts through 1) controlling stormwater in a manner to
mmmic the pre construction hydrology of the site 2) preserving and/or restoring
forested riparian buffers 3) installing and maintaining stringent sediment/erosion
control 4) mnmmnzatnon and careful installation of utility lines S) proper operation and
maintenance of equipment
Written comments were also received from the North Carolina Wildlife Resources
Commission (WRC) on April 9 2012 A copy of this correspondence is enclosed for your
consideration and response Specifically the WRC offered recommendations should the permit
be issued
1 Maintaining native forested buffers along streams and wetlands

- 2 -
2 Limiting fertilizers and pesticides as well as managing the stormwater and irrigation
runoff
3 Planting native buffers around stormwater or golf course ponds
4 Sediment and erosion control measures should be installed prior to any land clearing or
construction These measures should be routinely inspected and properly maintained
We received a comment letter from an Attorney in fact representing Myrtle M Cochrane
an adjacent/area property owner in response to the PN advertising this project In this letter
which was received after the comment period deadline concern was expressed over the
development and its impact on the drainage and runoff affecting Mrs Cochrane s property
Written comments stating no objection or no comment on the project were received from
the North Carolina Department of Cultural Resources and the National Marine Fisheries Service
While no response is necessary their correspondence is attached for your records
Your response to the comments identified above must be given full consideration before we
can make a final decision on your application We need your information to address the
concerns /issues raised over the proposed project You may submit additional information, revise
your plans to help resolve the issues rebut the issues made or request a decision based on the
existing record We must hear from you within 30 days otherwise your application will be
withdrawn If you have questions or comments please contact me at my Asheville Regulatory
Field Office address telephone [phone] ext 234
Sincerely
FILENAME SAW 2012 00482 PN Comment Ltr Final docx /nw
CESAW RG A/Kichefskn /s
MAIL
CESAW RG A/file
Steve Knchefskn
Regulatory Specialist
Asheville Regulatory Field Office
Enclosure
Copies Furnished (without enclosure)
Ms Karen Higgins
North Carolina Division of Water Quality
Wetlands Buffers Stormwater Compliance
and Permitting Unit
1650 Mail Service Center
Raleigh, North Carolina 27699 1650

- 3 -
Mr Brian Cole
Asheville Field Office
U S Fish and Wildlife Service
160 Zillicoa Street
Asheville, North Carolina 28801
Jeffrey Garnett
Wetlands and Marine Regulatory Section
Water Protection Div Region IV
U S Environmental Protection Agency
61 Forsyth Street SW
Atlanta, Georgia 30303
Ms Shan Bryant
North Carolina Wildlife Resource Commission
Piedmont Region Coordinator
Habitat Conservation Program
1721 Mail Service Center
Raleigh, North Carolina 27699 1721
Mr Wendell Overby
Soil & Environmental Consultants PA
11010 Raven Ridge Road
Raleigh, North Carolina 27614

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zilhcoa Street
Asheville North Carolina 28801
April 9 2012
Mr Steve Kichefski
US Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue Room 208
Asheville North Carolina 28801
Dear Mr Kichefski
This is the report of the U S Fish and Wildlife Service and the Department of the Interior on the
U S Army Corps of Engmeers (Corps) public notice (PN)(SAW -2012 00482) of an application
for an individual permit submitted by Mr Jonathan B Jarrett of Dillon Lakes LLC represented
by Mr Wendell Overby of Soil & Environmental Consultants Information for this report is
based on a review of the public notice issued by the Corps This report is submitted in
accordance with the provisions of the Fish and Wildlife Coordination Act as amended
(16 U S C 661 667e) the National Environmental Policy Act (42 U S C §4321 et seq ) the
Clean Water Act (33 U S C § 1251 et seq ) and section 7 of the Endangered Species Act of
1973 as amended (16 U S C 1531 1543) (Act)
Project Description According to the information provided, the purpose of the project is to
construct a comprehensive and integrated golf training facility The project consists of
constructing a clubhouse two cottages putting greens parking area, storm water facilities and
associated infrastructure The design of the golf training facility will include short game and
driving ranges areas along with (3) par three holes Aquatic impacts to wetlands and an open
water /pond are proposed for the project Total aquatic impacts associated with the project
include 0 38 acre of wetland and 2 44 -acres of open water No stream impacts are proposed for
this project
Federally Listed Species — Based on the project location and pictures obtained from the
Mecklenburg County GIS web site there appears to be suitable habitat for the federally
endangered Schweinitz s sunflower (Hehanthus schweinatzit) This plant has been found in close
proximity to the project site The project site contains a field roadsides and open woodland
areas all of which are suitable habitat for Schweinitz s sunflower Schweinitz s sunflower
occurs in relatively open habitats —road, power line and other maintained rights of way early
successional fields forest ecotonal margins, forest clearings etc The species thrives in full sun

but also grows in the light shade of open stands of oak pine hickory Schweimtz s sunflower
generally occurs on soils characterized as moist to dryxsh clays clay loams or sandy clay foams
that often have high gravel content The PN did not indicate whether surveys have been
conducted for this plant species within the project impact area. Unless an area has been
specifically surveyed for this species a survey should be conducted to ensure that this species is
not inadvertently lost Schweimtz s sunflower is difficult to identify at any time but even more
so outside the flowering season of late August to October so we recommend that surveys for this
species be conducted during this period In accordance with the Act it is the responsibility of
the appropriate federal agency or its designated representative to review its activities or programs
and to identify any such activities or programs that may affect endangered or threatened species
or their habitats If it is determined that the proposed activity may adversely affect any species
federally listed as endangered or threatened formal consultation with this office must be
mmated
Fish and Wildlife Resources — We are concerned about any potential direct and indirect impacts
that this project could have on aquatic resources that occur on the site It is important that you
minimize or avoid impacts to the aquatic resources located on the property According to the
404 (b)(1) guidelines no discharge or fill material shall be permitted in streams or wetlands if
there is a practicable alternative to the proposed discharge that would have less adverse impacts
on the aquatic ecosystem (40 CFR 230 10) therefore we recommend the following measures to
help mirumzze project impacts
Control storm water in a manner that will mimic the pre construction
hydrology of the project site We recommend the use of grassed swales in
place of curb and gutter and on site storm water management (i e
bioretention areas) that will result in no net change in the hydrology of the
watershed All storm water outlets should drain through a vegetated upland
area prior to reaching any stream or wetland area Sufficient retention designs
should be implemented to allow for the slow discharge of storm water
attenuating the potential adverse effects of storm water surges thermal spikes
and sediment, nutrient and chemical discharges
2 Preserve and/or restore forested riparian buffers Given the close proximity of
this project to aquatic resources and the increase of impervious surfaces that
will occur as a result of the development we are concerned about the loss and
lack of riparian buffers Forested riparian buffers a minimum of 100 feet
wide along perennial streams and 50 feet wide along intermittent streams,
should be created and/or maintained along all aquatic areas Riparian buffers
provide travel corridors and habitat for wildlife displaced by development In
addition riparian buffers protect water quality by stabilizing stream banks
filtering storm water runoff and providing habitat for aquatic and fisheries
resources
2

3 Install and maintain stringent measures to control erosion and sediment in
order to prevent unnecessary impacts to aquatic resources within and
downstream of the project site Disturbed areas should be reseeded with
native annual small grams that are appropriate for the season Fescue based
mixtures should be avoided If riparian vegetation is removed during
construction activities along streams we strongly recommend that native
riparian vegetation (including sedges grasses and rushes as well as native
woody species) in lieu of traditional hard treatments such as nprap be used to
stabilize the stream banks and to restore the riparian vegetation
Biodegradable erosion control matting should be used in conjunction with
appropriate seeding on disturbed soils in riparian areas Matting should be
secured in place with staples stakes or live stakes of native trees (whenever
possible) Pen -meter erosion control devices should be installed prior to any
on the ground activities Frequent maintenance of these devices is critical to
their proper function in order to minimize sediment discharge from the project
site Frequent maintenance of these devices is critical to their proper function
in order to minimize sediment discharge from the project site Perimeter
erosion control devices should be installed prior to any on the - ground
activities
4 Install utility lines (i e , sewer gas water) outside the above recommended
buffer widths All utility crossings should be kept to a minimum, and all utility
infrastructure should be kept out of riparian buffer areas The directional bore
stream crossing method (installation of utilities beneath the riverbed avoiding
impacts to the stream and buffer) should be used for utility crossings
Manholes or similar access structures should not be allowed within buffer
areas Stream crossings should be near perpendicular to stream flow and
should be monitored at least every 3 months for maintenance needs during the
first 24 months of the project and annually thereafter Sewer lines associated
with crossing areas should be maintained and operated at all times to prevent
discharges to land or surface waters In circumstances where minimum
setbacks cannot be attained sewer lines shall be constructed of ductile iron or a
substance of equal durability
5 Keep equipment out of streams by operating from the banks in a fashion that
minimizes disturbance to woody vegetation Equipment should be inspected
daily and should be maintained to prevent the contamination of surface waters
from leaking fuels lubricants hydraulic fluids, or other toxic materials All
fuels lubricants and other toxic materials should be stored outside the riparian
management area of the stream, iii a location where the material can be
contained Equipment should be checked for leaks of hydraulic fluids cooling
system liquids and fuel and should be cleaned before fording any stream
Also all fueling operations should be accomplished outside the riparian
management area.

We appreciate the opportunity to provide these comments If we can be of assistance or if you
have any questions please do not hesitate to contact Mr Bryan Tompkins of our staff at
828/258 3939 Ext 240 In any future correspondence concerning this project please reference
our Log Number 4 2 12 132
Sincerely
original signed
Brian P Cole
Field Supervisor
4

EU North Carolina Wildlife Resources Commission
Gordon Myers Executive Director
MEMORANDUM
TO Steve K.ichefski, Asheville Regulatory Field Office
U S Army Corps of Engineers
FROM Shari L Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE 9 April 2012
SUBJECT Public Notice for Dillon Lakes LLC for Construction of a Carolina Golf Lodge
Charlotte Mecklenburg County North Carolina Corps Action ID # SAW 2012 00482
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document Our comments are provided in accordance with provisions of the Clean Water Act of
1977 (as amended) Fish and Wildlife Coordination Act (48 Stat 401 as amended 16 U S C 661 667e)
and North Carolina General Statutes (G S 113 131 et seq )
The applicant proposes to permanently impact 0 38 acres of wetlands and 2 44 acres of open
water to construct a golf training facility including a clubhouse two cottages putting green parking area,
stormwater facilities and other associated infrastructure The purpose of the project is to construct a
comprehensive and integrated golf training facility Mitigation for the project includes payment into the
N C Ecosystem Enhancement Program and preservation of the remaining jurisdictional features
including 0 188 acres of wetlands 0 33 acres of open water and 1 030 lmear feet of stream channel by
declaration of conservation
The project site drains to an unnamed tributary to Irwms Creek in the Catawba River Basin.
According to the Public Notice the proposed wetland impacts would occur to features that formed after
two ponds were drained in 2003 and the open water impacts would occur to a man made feature No
stream impacts are proposed for the project
Should the permit be issued, we offer the following recommendations to minimize impacts to
aquatic and terrestrial wildlife resources
1 Maintain a minimum 100 foot undisturbed native forested buffer along each side of perennial
streams and 50 foot undisturbed, native forested buffer along each side of intermittent streams and
wetlands Riparian buffers provide habitat areas for aquatic and terrestrial wildlife species and travel
corridors for terrestrial wildlife In addition riparian buffers protect water quality by stabilizing
stream banks and filtering stormwater runoff
Mailing Address Division of Inland Fisheries 1721 Mail Service Center Raleigh NC 27699 1721
Telephone [phone] Fax [phone]

Page 2
9 April 2012
Carolina Golf Lodge
Corps Action ID No SAW 2012 00482
2 Limit application of fertilizers and pesticides within riparian buffers and use non chemical control
measures wherever possible Stormwater and irrigation runoff from greens and tees should be
retained and not be allowed to discharge directly to surface waters Constructing wetlands near
greens and tees may be helpful in treating runoff pollutants such as fertilizers and pesticides
3 Where feasible native trees and shrubs should be planted around stormwater or golf course ponds to
provide avian and terrestrial habitat and to reduce exposure of the water surface to sunlight These
should provide habitat benefits that could offset those functions lost by development partially restore
aquatic habitats reduce exposure of the water surface to sunlight thereby minimizing thermal
pollution and provide essential summer and winter habitats
4 Sediment and erosion control measures should be installed prior to any land clearing or construction
These measures should be routinely inspected and properly maintained Excessive silt and sediment
loads can have numerous detrimental effects on aquatic resources including destruction of spawning
habitat suffocation of eggs and clogging of gills of aquatic species
Thank you for the opportunity to comment on this project If we can provide further assistance
please contact our office at [phone] or shah bryantRncwildlife org
ec Alan Johnson, NCDWQ

April 25 2012
Steve Kichefski�� ? 0 26112
Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue Room 208
Asheville NC 28801 5006
Mr Kichefski
I have lust received the Public Notice (Action# SAW 2012 00482) regarding the
application from Mr Jonathan B Jarrett for construction of a golf training facility in
Charlotte N C The issue date was March 29 the deadline was April 12 and I received it
April 9 consequently I have not had adequate time to respond and this response is late
I am the Attorney in Fact for Mrs W E Cochrane owner the property which adjoins
the property in question at its northeast corner We would lake to express our concern over
the development and its impact on the drainage and runoff affecting Mrs Cochrane s
property The property is currently on the market and she cannot afford to be adversely
affected by the project.
Has a hearing been requested regarding the development and if so I would lake the
details so I might attend If there are any additional findings or impact statements I would
lake copies of those
I await your reply
Cyrus S Hapgood
Attorney in Fact for Myrtle M Cochrane

Mecklenburg County NC POLARIS
Page 1 of 1
Aecklenburg County North Carolina
POLARIS
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iplanunetnc maps and other public records and data Users of this map are hereby notified that the aforemenhoned public primary mformabon
,sources should be consulted for verification Meddenburg County and ds mapping contractors assume no legal responsibirdy for the mformabon
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http //polans mecklenburgcountync gov /servlet/comesn esnmap Esnmap ?ServtceName = 5/21/2012

Soil & Environmental Consultants, PA
11010 Raven Ridge Road Raleigh, North Carolina 27614 Phone [phone] Fax [phone]
www SandEC coin
May 29 2012
S &EC Project # 11762
To US Army Corps of Engineers
Asheville Regulatory Field Office
Attn Mr Steve Kichefski
151 Patton Avenue Room 208
Asheville North Carolina 28801
N C Division of Water Quality
WebSCaPe
Attn Ms Karen Higgins
512 N Salisbury Street 9h floor
Raleigh NC 27603
From Soil & Environmental Consultants P A
Attn Wendell Overby
11010 Raven Ridge Road
Raleigh NC 27614
Re CAROLINA GOLF LODGE — PUBLIC NOTICE RESPONSES
INDIVIDUAL PERMIT APPLICATION
U S Army Corps of Engineers Action ID No 2012 00482
Dear Mr Kichefski and Ms Higgins
On behalf of the owner Dillon Lakes LLC we are hereby providing additional
information in response to comments received during the Public Notice period This additional
information is an amendment to our existing Individual Permit application under review by both
the USACE (Action ID No 2012 00482) and DWQ (DWQ Project #12 0053) for the proposed
Carolina Golf Lodge project
PUBLIC NOTICE
The USACE Public Notice was issued on March 29 2012 The comment period for this Public
Noticed expired on April 12 2012 The USACE received written comments from the U S Fish
and Wildlife Services (USFWS) dated April 9 2012 N C Wildlife Resources Commission
(WRC) dated April 9 2012 (see attached) and an Attorney in Fact representing Myrtle M
Page 1 of 5

Carolina Golf Lodge — Individual Permit
Additional Information
May 29 2012
S &EC PA 11762
Cochrane dated April 25 2012 (see attached) Written comments were also submitted by the
North Carolina Department of Cultural Resources (DCR) and the National Marine Fishenes
Service (NMFS) The DCR and NMF had no objection or no comment on the project No other
written comments were received as of the expiration of the comment period
ADDITIONAL INFORMATION
USACE May 14, 2012 Letter (attached)
The USACE requested responses to three comment letters received either prior to or shortly
after the close of the comment period including the aforementioned USFWS WRC and
Attorney in Fact for Myrtle M Cochrane
USFWS April 9, 2012 Letter (attached)
The Apn19 2012 letter from the USFWS is summarized by the USACE as having 2 main
concerns including 1) habitat for the federally endangered Schweinitz s sunflower
(Helianthus schweinitzii) and 2) potential direct and indirect impacts the project could have
on aquatic resources that occur on the site The USFWS provided recommendations to
minimize impacts including 1) controlling stormwater in a manner to mimic the pre
construction hydrology of the site 2) preserving and/or restoring forested riparian buffers 3)
installing and maintaining stringent sediment/erosion control 4) minimization and careful
installation of utility lines and 5) proper operation and maintenance of equipment
1 Schweinitz s sunflower habitat
A survey for the Schweinitz s sunflower (Helianthus schwecnctzu) has not been
performed within project boundaries As documented in the USFWS letter the plant is
difficult to identify especially outside the flowering season of late August to October As
part of the applicant s due diligence efforts S &EC reviewed data available from the
Natural Heritage Program (NHP) on February 8 2012 regarding the presence of
Schweinitz s sunflower on the project site Based on S &EC s review of the NHP data
no occurrence of Schweinitz s sunflower is listed within 5 miles of Carolina Golf Lodge
Suitable habitat for Helianthus schwecnctzu includes field roadsides and open woodland
areas According to the USFWS the plant occurs in relatively open habitats road power
line and other maintained rights of way early successional fields forest ecotonal
margins forest cleanngs etc The USFWS letter further provides Helianthus
schwecnctzu occurs on soils charactenzed as moist to dryish clays clay loams or sandy
clay loams Carolina Golf Lodge like most rural parcels in Mecklenburg County
contains clay based soils with field edges forest clearings and rights of way Based on
the generic habitat requirements flowering season period and lack of known occurrences
within 5 miles of the site we believe that a survey for Helianthus schwenitzic should not
be required
2 Direct and Indirect Impacts to Aquatic Resources
The applicant has made every attempt to minimize impacts to wetland streams and open
waters on site while still maintaining a viable project and meeting the project purpose as
Page 2 of 5

Carolina Golf Lodge — Individual Permit
Additional Information
May 29 2012
S &EC PA 11762
described in the original application package Alternative project designs were evaluated
to determine which alternative accomplishes the project purpose with the least adverse
impact on the aquatic ecosystem No stream impacts are proposed for the project and
impacted features are man made in origin (e g pond and drained pond wetlands)
Furthermore the applicant will mitigate for permanent losses to wetlands via payment to
the NC Ecosystem Enhancement Program (EEP)
1 Stormwater Management
Carolina Golf Lodge will require a grading permit for construction A
stormwater management plan is also required by local and state agencies with the
City of Charlotte to review and approve finalized plans The proposed
stormwater plan will be designed per current DWQ Best Management Practices
Manual to remove 85% Total Suspended Solids (TSS) for impervious areas
Operation and maintenance agreements will be required for SMP approval A
final SMP will be provided to NC DWQ prior to commencement of approved
impacts to jurisdictional waters We do not anticipate any negative downstream
water quality or flooding impacts associated with stormwater runoff from the site
and in fact believe this project has the potential to improve the current
downstream water quality with the installation of appropriate stormwater BMPs
In addition to the water quality aspects the stormwater pond will detain
stormwater so that the post development peak flows for the 10 and 25 year storm
mimics the pre development conditions In other words the post development
hydrology will mimic the pre development conditions
2 Riparian Buffers
If the latest Exhibit A — Preferred Alternative (attached) is accepted by the
USACE then the applicant will maintain 188 acres of wetlands 1 030 feet of
streams and 0 33 acres of open waters on site protected in a declaration of
conservation Additionally there are no plans by the applicant to impact wetland
#1 (Ill acres) and Pond C (5 08 acres) In addition to conserving jurisdictional
features the configuration of Carolina Golf Lodge will result in undisturbed areas
(e g riparian buffers) adjacent to streams #1 and #2
3 Erosion and Sediment Control
In order to obtain a grading permit for construction Carolina Golf Lodge will
follow erosion and sediment control plans required by the City of Charlotte under
the North Carolina Sediment Control Law These plans will incorporate
requirements set by the City of Charlotte regarding use and installation of silt
fence use of skimmers to dewater sediment ponds from the top and the timely
establishment of vegetation on disturbed areas The project will obtain an
approved erosion control plan from the City and maintain the plan throughout
construction The City of Charlotte is an NC DWQ locally delegated authority
for erosion and sediment control approval
Page 3 of 5

Carolina Golf Lodge — Individual Pernut
Additional Information
4 Installation of Utility Lines
May 29 2012
S &EC PA 11762
The applicant will take all precautions to keep utility lines outside jurisdictional
Waters and riparian buffers
5 Equipment Operation and Maintenance
Fueling operations will be conducted outside of the npanan/conservation areas
and away from Waters Equipment will be kept out of streams and Waters
WRC April 9, 2012 Letter (attached)
The WRC provided four recommendations to the USACE
1 Maintaining native forested buffers along streams and wetlands
If the latest Exhibit A - Preferred Alternative (attached) is accepted by the USACE then
the applicant will maintain 188 acres of wetlands 1 030 feet of streams and 0 33 acres of
open waters on site protected in a declaration of conservation Additionally there are no
plans by the applicant to impact wetland #1 ( 111 acres) and Pond C (5 08 acres) In addition
to conserving jurisdictional features the configuration of Carolina Golf Lodge will result in
undisturbed areas (e g riparian buffers) adjacent to streams #1 and #2
2 Limiting Fertilizers and Pesticides / Stormwater and Irrigation Runoff
The Carolina Golf Lodge will use fertilizers on the greens and fairways to establish and
maintain course grass Fertilizers and pesticides will not be used in riparian buffers and
Waters Drains underlying course greens will not be discharged directly to Waters
Algae blooms will be controlled through low phosphorus inputs of not more than 1
pound annually applied and slow release low soluble fertilizers to minimize nutrient
runoff to surface waters
3 Planting Native Buffers Around Stormwater or Golf Course Ponds
Where practical the applicant will plant native vegetation around stormwater facilities
and on site ponds Stormwater management plans will be designed to meet or exceed
current DWQ BMP requirements
4 Sediment and Erosion Control Measures
In order to obtain a grading permit for construction Carolina Golf Lodge will follow
erosion and sediment control plans required by the City of Charlotte under the North
Carolina Sediment Control Law These plans will incorporate requirements set by the
City of Charlotte regarding use and installation of silt fence use of skimmers to dewater
sediment ponds from the top and the timely establishment of vegetation on disturbed
areas The project will obtain an approved erosion control plan from the City and
maintain the plan through out construction The City of Charlotte is an NC DWQ locally
delegated authority for erosion and sediment control approval
Page 4 of 5

Carolina Golf Lodge — Individual Permit May 29 2012
Additional Information S &EC PA 11762
Myrtle M Cochrane April 25, 2012 Letter (attached)
A letter from Mrs Myrtle M Cochrane s Attorney in Fact was received by the USACE on
April 30 2012 after the public notice comment period The letter expressed Mrs Cochrane s
concern over the potential impact of Carolina Golf Lodge on drainage and runoff affecting
her property In addition the letter expressed concern over any negative affects Carolina
Golf Lodge may have regarding Mrs Cochrane s ability to sell her property
Mrs Cochrane s property is located at the northeast corner of the Carolina Golf Lodge (see
attached Mecklenburg County GIS map) Mrs Cochrane s property occurs uphill and more
importantly upstream of the subject property The stream on Mrs Cochrane s property flows
into the largest open water (Pond C) on Carolina Golf Lodge No changes of pre
development water levels to Pond C are expected for the proposed development As a result
drainage and runoff will not be affected on Mrs Cochrane s property It is our opinion that
construction of a world class golf training facility will not negatively affect the ability of Mrs
Cochrane to sell her property
CONCLUSION
It is our understanding that this additional information will provide you all of the information
required for you to continue the review of this permit application Please contact us if you require
any information beyond what has been provided in this response We appreciate your review and
comments
Sincerely
Soil & Environmental Consultants PA
Wi*,W
Wendell Overby
NC Licensed Soil S entist
NC Registered Forester
Attachments Exhibit A Preferred Alternative" Site Plan
USACE May 14, 2012 Letter
USFWS April 9, 2012 Letter
WRC April 9, 2012 Letter
Myrtle M Cochrane April 25, 2012 Letter
Mecklenburg County `Polaris' GIS Map
Page 5 of 5

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32612

May 14 2012
Regulatory Division
Action ID SAW 2012 00482
Mr Jonathan B Jarrett
Dillon Lakes LLC
817 Romany Road
Charlotte North Carolina 28203
Dear Mr Jarrett
Reference is made to the application of March 14 2012 for individual Department of the
Army (DA) permit authorization to permanently impact impact 0 38 acres wetland and 2 44 acre
of open water associated with the construction of a golf training facility in Charlotte
North Carolina.
After review of your proposal the United States Department of Interior Fish and Wildlife
Services ( USFWS) submitted comments by letter dated April 9 2012 A copy of this letter is
enclosed for your consideration and response Specifically the USFWS stated the following
1 Based on project location and pictures obtained from the Mecklenburg County GIS
websrte there appears to be suitable habitat for the federally endangered Schwemrtz s
sunflower (Hehanthus schweinazti) Unless the area has been specifically surveyed for
this species a survey should be conducted to ensure that this species is not
inadvertently lost
2 They also expressed concern about any potential direct and indirect impacts that this
project could have on aquatic resources that occur on the site Therefore they
recommend minimization of impacts through 1) controlling stormwater in a manner to
mimic the pre construction hydrology of the site 2) preserving and/or restoring
forested riparian buffers 3) installing and maintaining stringent sediment/erosion
control 4) minimization and careful installation of utility lines 5) proper operation and
maintenance of equipment
Written comments were also received from the North Carolina Wildlife Resources
Commission (WRC) on April 9 2012 A copy of this correspondence is enclosed for your
consideration and response Specifically the WRC offered recommendations should the permit
be issued
1 Maintaining native forested buffers along streams and wetlands

- 2 -
2 Limiting fertilizers and pesticides as well as managing the stormwater and irrigation
runoff
3 Planting native buffers around stormwater or golf course ponds
4 Sediment and erosion control measures should be installed prior to any land clearing or
construction These measures should be routinely inspected and properly maintained
We received a comment letter from an Attorney in fact representing Myrtle M Cochrane
an adjacent/area property owner in response to the PN advertising this project In this letter
which was received after the comment period deadline concern was expressed over the
development and its impact on the drainage and runoff affecting Mrs Cochrane's property
Written comments stating no objection or no comment on the project were received from
the North Carolina Department of Cultural Resources and the National Marine Fisheries Service
While no response is necessary their correspondence is attached for your records
Your response to the comments identified above must be given full consideration before we
can make a final decision on your application We need your information to address the
concerns /issues raised over the proposed project You may submit additional information, revise
your plans to help resolve the issues rebut the issues made or request a decision based on the
existing record We must hear from you within 30 days otherwise your application will be
withdrawn If you have questions or comments please contact me at my Asheville Regulatory
Field Office address telephone (828) -271 7980 ext 234
Sincerely,
FILENAME SAW 2012 00482 PN Comment Ltr Final docx /nw
CESAW RG A/Kichefski /s
MAIL
CESAW RG. A/file
Steve Kichefski
Regulatory Specialist
Asheville Regulatory Field Office
Enclosure
Copies Furnished (without enclosure)
Ms Karen Higgins
North Carolina. Division of Water Quality
Wetlands, Buffers Stormwater Compliance
and Permitting Unit
1650 Mail Service Center
Raleigh, North Carolina 27699 1650

- 3 -
Mr Brian Cole
Asheville Field Office
U S Fish and Wildlife Service
160 Zillicoa Street
Asheville North Carolina 28801
Jeffrey Garnett
Wetlands and Marine Regulatory Section
Water Protection Div Region IV
U S Environmental Protection Agency
61 Forsyth Street SW
Atlanta, Georgia 30303
Ms Shan Bryant
North Carolina Wildlife Resource Commission
Piedmont Region Coordinator
Habitat Conservation Program
1721 Mail Service Center
Raleigh, North Carolina 27699 1721
Mr Wendell Overby
Soil & Environmental Consultants PA
11010 Raven Ridge Road
Raleigh, North Carolina 27614

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zilhcoa Street
Asheville North C -irohna28801
April 9 2012
Mr Steve Kichefski
US Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue Room 208
Asheville North Carolina 28801
Dear Mr Kichefski
This is the report of the U S Fish and Wildlife Service and the Department of the Interior on the
U S Army Corps of Engineers (Corps) public notice (PN)(SAW- 2012 - 00482) of an application
for an individual permit submitted by Mr Jonathan B Jarrett of Dillon Lakes LLC represented
by Mr Wendell Overby of Soil & Environmental Consultants Information for this report is
based on a review of the public notice issued by the Corps This report is submitted in
accordance with the provisions of the Fish and Wildlife Coordination Act as amended
(16 U S C 661 667e) the National Environmental Policy Act (42 U S C §4321 et seq ) the
Clean Water Act (33 U S C § 1251 et seq ) and section 7 of the Endangered Species Act of
1973 as amended (16 U S C 1531 1543) (Act)
Project Description According to the information provided, the purpose of the project is to
construct a comprehensive and integrated golf training facility The project consists of
constructing a clubhouse two cottages putting greens parking area, storm water facilities and
associated infrastructure The design of the golf trammg facility will include short game and
driving ranges areas along with (3) par three holes Aquatic impacts to wetlands and an open
water /pond are proposed for the project Total aquatic impacts associated with the project
include 0 38 acre of wetland and 2 44- acres of open water No stream impacts are proposed for
this project
Federally Listed Species – Based on the project location and pictures obtained from the
Mecklenburg County GIS web site there appears to be suitable habitat for the federally
endangered Schweinitz s sunflower (Helaanthus schweinatzrt) This plant has been found in close
proximity to the project site The project site contains a field, roadsides and open woodland
areas all of which are suitable habitat for Schwemitz s sunflower Schweinitz s sunflower
occurs m relatively open habitats —road, power lme and other maintained rights of way early
successional fields forest ecotonal margins forest clearings etc The species thnves in full sun

but also grows in the light shade of open stands of oak pme hickory Schwemitz s sunflower
generally occurs on soils characterized as moist to dryish clays clay loans or sandy clay loams
that often have high gravel content The PN did not indicate whether surveys have been
conducted for this plant species within the project impact area. Unless an area has been
specifically surveyed for this species a survey should be conducted to ensure that this species is
not inadvertently lost Schweinitz s sunflower is difficult to identify at any tune but even more
so outside the flowering season of late August to October so we recommend that surveys for this
species be conducted durmg this period In accordance with the Act it is the responsibility of
the appropriate federal agency or its designated representative to review its activities or programs
and to identify any such activities or programs that may affect endangered or threatened species
or their habitats If it is determined that the proposed activity may adversely affect any species
federally listed as endangered or threatened formal consultation with this office must be
initiated
Fish and Wildlife Resources — We are concerned about any potential direct and indirect impacts
that this project could have on aquatic resources that occur on the site It is important that you
minimize or avoid impacts to the aquatic resources located on the property According to the
404 (b)(1) guidelines no discharge or fill material shall be permitted in streams or wetlands if
there is a practicable alternative to the proposed discharge that would have less adverse impacts
on the aquatic ecosystem (40 CFR 230 10) therefore we recommend the following measures to
help minimize project impacts
Control storm water in a manner that will mimic the pre construction
hydrology of the project site We recommend the use of grassed swales in
place of curb and gutter and on site storm water management (i e
bioretention areas) that will result in no net change in the hydrology of the
watershed All storm water ,outlets should dram through a vegetated upland
area prior to reaching any stream or wetland area Sufficient retention designs
should be implemented to allow for the slow discharge of storm water
attenuating the potential adverse effects of storm water surges thermal spikes
and sediment, nutrient, and chemical discharges
2 Preserve and/or restore forested riparian buffers Given the close proximity of
this project to aquatic resources and the increase of impervious surfaces that
will occur as a result of the development we are concerned about the loss and
lack of riparian buffers Forested riparian buffers a minimum of 100 feet
wide along perennial streams and 50 feet wide along intermittent streams
should be created and/or maintained along all aquatic areas Riparian buffers
provide travel corridors and habitat for wildlife displaced by development In
addition riparian buffers protect water quality by stabilizing stream banks
filtering storm -water runoff and providing habitat for aquatic and fisheries
resources
2

3 Install and maintain stringent measures to control erosion and sediment in
order to prevent unnecessary impacts to aquatic resources within and
downstream of the project site Disturbed areas should be reseeded with
native annual small grams that are appropriate for the season Fescue based
mixtures should be avoided If riparian vegetation is removed during
construction activities along streams we strongly recommend that native
riparian vegetation (including sedges grasses, and rushes as well as native
woody species) in lieu of traditional hard treatments such as nprap be used to
stabilize the stream banks and to restore the riparian vegetation
Biodegradable erosion control matting should be used in conjunction with
appropriate seedmg on disturbed soils in riparian areas Matting should be
secured in place with staples stakes or live stakes of native trees (whenever
possible) Perimeter erosion control devices should be installed prior to any
on the ground activities Frequent maintenance of these devices is critical to
their proper function in order to minimize sediment discharge from the project
site Frequent maintenance of these devices is critical to their proper function
in order to minimize sediment discharge from the project site Perimeter
erosion control devices should be installed prior to any on the ground
activities
4 Install utility lines (i e , sewer gas water) outside the above recommended
buffer widths All utility crossings should be kept to a minimum, and all utility
infrastructure should be kept out of riparian buffer areas The directional bore
stream crossing method (installation of utilities beneath the riverbed avoiding
impacts to the stream and buffer) should be used for utility crossings
Manholes or similar access structures should not be allowed within buffer
areas Stream crossings should be near perpendicular to stream flow and
should be monitored at least every 3 months for maintenance needs during the
first 24 months of the project and annually thereafter Sewer lines associated
with crossing areas should be maintained and operated at all times to prevent
discharges to land or surface waters In circumstances where mimmum
setbacks cannot be attained sewer lines shall be constructed of ductile iron or a
substance of equal durability
5 Keep equipment out of streams by operating from the banks in a fashion that
minimizes disturbance to woody vegetation Equipment should be inspected
daily and should be maintained to prevent the contamination of surface waters
from leaking fuels, lubricants hydraulic fluids or other toxic materials All
fuels, lubricants and other toxic materials should be stored outside the riparian
management area of the stream, in a location where the material can be
contained Equipment should be checked for leaks of hydraulic fluids, cooling
system liquids and fuel and should be cleaned before fording any stream
Also all fueling operations should be accomplished outside the riparian
management area.

We appreciate the opportunity to provide these comments If we can be of assistance or if you
have any questions please do not hesitate to contact Mr Bryan Tompkins of our staff at
828/258 3939 Ext 240 In any future correspondence concerning this project please reference
our Log Number 4 2 12 132
Sincerely
original signed
Brian P Cole
Field Supervisor
EI

'Ks:-'�' North Carolina Wildlife Resources Commission
Gordon Myers Executive Director
MEMORANDUM
TO Steve Kichefski, Asheville Regulatory Field Office
U S Army Corps of Engineers
FROM Shan L Bryant Piedmont Region Coordinator �hc.�`�ii,' t►,
Habitat Conservation Program
DATE 9 Apn12012
SUBJECT Public Notice for Dillon Lakes LLC for Construction of a Carolina Golf Lodge
Charlotte Mecklenburg County North Carolina Corps Action ID # SAW 2012 00482
Biologists with the North Carolina Wildhfe Resources Commission (NCWRC) have reviewed the
subject document Our comments are provided in accordance with provisions of the Clean Water Act of
1977 (as amended) Fish and Wildlife Coordination Act (48 Stat 401 as amended 16 U S C 661 667c)
and North Carolina General Statutes (G S 113 131 et seq )
The applicant proposes to permanently impact 0 38 acres of wetlands and 2 44 acres of open
water to construct a golf training facility including a clubhouse two cottages putting green parking area
stormwater facilities and other associated infrastructure The purpose of the protect is to construct a
comprehensive and integrated golf training facihty Mitigation for the project includes payment into the
N C Ecosystem Enhancement Program and preservation of the remauiing jurisdictional features
including 0 188 acres of wetlands 0 33 acres of open water and 1 030 linear feet of stream channel by
declaration of conservation
The project site drams to an unnamed tributary to Irwins Creek m the Catawba River Basin.
According to the Public Notice the proposed wetland impacts would occur to features that formed after
two ponds were drained in 2003 and the open water impacts would occur to a man made feature No
stream impacts are proposed for the project
Should the permit be issued, we offer the following recommendations to minims a impacts to
aquatic and terrestrial wildlife resources
1 Maintain a min imum 100 foot undisturbed native forested buffer along each side of perennial
streams and 50 foot undisturbed, native forested buffer along each side of intermittent streams and
wetlands Ripanan buffers provide habitat areas for aquatic and terrestnal wildlife species and travel
corridors for terrestrial wildlife In addition riparian buffers protect water quality by stabilizing
stream banks and filtering stormwater runoff
Mailing Address Division of Inland Fisheries 1721 Mail Service Center Raleigh NC 27699 1721
Telephone [phone] Fax [phone]

Page 2
9 April 2012
Carolina Golf Lodge
Corps Action ID No SAW 2012 00482
Limit application of fertilizers and pesticides within riparian buffers and use non chemical control
measures wherever possible Stormwater and irrigation runoff from greens and tees should be
retained and not be allowed to discharge directly to surface waters Constructing wetlands near
greens and tees may be helpful in treating runoff pollutants such as fertilizers and pesticides
Where feasible native trees and shrubs should be planted around stormwater or golf course ponds to
provide avian and terrestrial habitat and to reduce exposure of the water surface to sunlight These
should provide habitat benefits that could offset those functions lost by development partially restore
aquatic habitats reduce exposure of the water surface to sunlight thereby minimizing thermal
pollution and provide essential summer and winter habitats
Sediment and erosion control measures should be installed prior to any land clearing or construction
These measures should be routinely inspected and properly maintained Excessive silt and sediment
loads can have numerous detrimental effects on aquatic resources including destruction of spawning
habitat suffocation of eggs and clogging of gills of aquatic species
Thank you for the opportunity to comment on this protect if we can provide further assistance
please contact our office at (33 6) 449 7625 or share bUant(@ncwildlife org
ec Alan Johnson, NCDWQ

April 25 2012
Steve Kichefski �ct� f1 2012
Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue Room 208
Asheville NC 28801 5006
Mr Kichefski
I have just received the Public Notice (Action# SAW 2012 00482) regarding the
application from Mr Jonathan B Jarrett for construction of a golf training facility in
Charlotte N C The issue date was March 29 the deadline was April 12 and I received it
April 9 consequently I have not had adequate time to respond and this response is late
I am the Attorney in Fact for Mrs W E Cochrane owner the property which adjoins
the property in question at its northeast corner We would like to express our concern over
the development and its impact on the drainage and runoff affecting Mrs Cochrane s
property The property is currently on the market and she cannot afford to be adversely
affected by the project.
Has a hearing been requested regarding the development and if so I would like the
details so I might attend If there are any additional findings or impact statements I would
like copies of those
I await your reply
Cyrus S Hapgood
Attorney in Fact for Myrtle M Cochrane

Mecklenburg County NC POLARIS Page 1 of 1
pecwenburg County North Carolina -
POLARIS
Property Ownership Land Records Information System — -
- —_Date Pnnb cL Mon May 2115 47 55 EDT 2012
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