HomeMy WebLinkAbout20180765 Ver 5_More Information Received_20210307Staff Review
Does this application have all the attachments needed to accept it into the review process?*
r Yes r No
ID#* Version* 5
20180765
Is this project a public transportation project?* r Yes
r No
Reviewer List:* Kaylie Yankura:eads\kyankura
Select Reviewing Office:* Asheville Regional Office - (828) 296-4500
Does this project require a request for payment to be sent?*
r
Yes
r
No
Project Submittal Form
Please note: fields marked with a red asterisk below are required. You will not be able to submit the form until all
mandatory questions are answered.
Project Type: * r
For the Record Only (Courtesy Copy)
r
New Project
r
Modification/New Project with Existing ID
r
More Information Response
r
Other Agency Comments
r
Pre -Application Submittal
r
Re-Issuance\Renewal Request
r
Stream or Buffer Appeal
Is this supplemental information that needs to be sent to the Corps?*
r Yes r No
Project Contact Information
Name: R. Clement Riddle
Who is subrritting the inforrration?
Email Address: clement@cwenv.com
Project Information
Existing ID #: Existing Version:
20180765 3
20170001(no dashes) 1
Project Name: Hlgh Hampton Redevelopment
Is this a public transportation project?
r Yes
r No
Is the project located within a NC DCM Area of Environmental Concern (AEC)?
r Yes r No r Unknown
County (ies)
Jackson
Please upload all files that need to be submited.
aick the upload button or drag and drop files here to attach document
918 DWR Agency Response letter 3.1.21.pdf 481.5KB
Holes 1 and 9 Figure C-100 Impact As -Built 12-21-
121.4K6
20.pdf
Holes 1 and 9 Figure C-405 Stream Buffer Plans
807.81 KB
revised 4-14-20.pdf
Holes 1 and 9 Trout Buffer Variance Figure 405
687.64K6
9.24.18. pdf
Impact As -Built Tables 12.20.21.pdf 183.85KB
Only pdf or krm files are accepted.
Describe the attachments
or comments:
Response to DWR comment letter dated 9.21.20
Sign and Submit
P By checking the box and signing box below, I certify that:
■ I, the project proponent, hereby certifies that all information contained herein is true, accurate, and complete to
the best of my knowledge and belief.
■ I, the project proponent, hereby requests that the certifying authority review and take action on this CWA 401
certification request within the applicable reasonable period of time.
■ I agree that submission of this online form is a "transaction" subject to Chapter 66, Article 40 of the NC General
Statutes (the "Uniform Electronic Transactions Act');
■ I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General
Statutes (the "Uniform Electronic Transactions Act');
■ 1 understand that an electronic signature has the same legal effect and can be enforced in the same way as a
written signature; AND
■ I intend to electronically sign and submit the online form.
Signature:
Submittal Date: Is filled in autocratically.
DocuSign Envelope ID: C5722192-190B-4C6C-9866-6073E4050C94
aLer
C1earWater Environmental Consultants, Inc.
www.cwenv.com
March 5, 2021
Paul Wojoski
NC DEQ, Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: High Hampton Redevelopment
DWR # 20180765 Ver 3
Jackson County, North Carolina
Mr. Wojoski,
Please reference the letter dated September 21, 2020 sent by the NC Division of Water Resources
(DWR) in response to the permit modification request submitted by C1earWater Environmental
Consultants, Inc. (CEC), on behalf of Daniel Communities. The permit modification requested
authorization for the impacts associated with the High Hampton Redevelopment Plan. The
comments provided by the DWR in response to this plan are listed and discussed below.
NC Division of Water Resources comments:
1. The modification application indicates that the new impact areas being requested were
previously proposed as impacts for golf holes I through 9. The application also notes that
through redesign these areas were proposed to be avoided. Please provide a copy of the
original detailed design ofgolfholes I through 9 which shows impacts to the areas noted
in the modification request, and a copy of the revised detailed design ofgolfholes I through
9 which shows avoidance of impacts to the areas noted in the modification request. The
Division is unclear how the current proposal meets avoidance and minimization when the
approved design avoids impacts to these areas.
Enclosed with this submittal in Attachment A is the following:
The submitted golf course layout for holes 1 and 9 (Figure 405, dated
September 2018). The stream impact was approved by NC DWR on
January 21, 2020.
145 7' Avenue West, Suite B
Hendersonville, NC 28792
828-698-9800 Tel
DocuSign Envelope ID: C5722192-190B-4C6C-9866-6073E4050C94
Mr. Sue Homewood
March 5, 2021
Page 2 of 3
2. The planned redesign (Figure C-405 revised April 14, 2020). The revised
plan was submitted with the permit modification and this redesign was an
attempt to reduce stream impacts and mitigation at this location and other
areas within the project.
3. Figure C-100 is the as -built survey of edge of disturbance completed in and
submitted to DWR on December 21, 2020.
2. The Division is unclear how unexpected inconsistencies with contours align with proposed
and revised impacts/designs. Please further explain the unexpected inconsistencies which
occurred and explain how these inconsistencies are unique to this site within the project.
In order to ensure compliance with the Individual Water Quality Certification issued by
the Division, it is required that you provide a detailed list of all approved impacts
indicating which impacts have occurred to date. For any impacts that have not occurred
as of the date of this letter, you are required to provide a detailed survey of the impact
area/location with the proposed impact shown to the Division to ensure there are no further
inconsistencies within the project.
On December 21, 2020, CEC submitted, via email, the requested as -built surveys and
accounting of all stream and wetland impacts that have occurred within the project
(Attachment B). On February 4, 2021, we met with Ms. Sue Homewood, DWR, Ms.
Kaylie Yankura, DWR, and Mr. David Brown, Corps of Engineers (Corps), on -site to
review and confirm as -built impacts. During this meeting, additional information was
requested specific to two locations described below.
Holes 1 and 9
On April 2, 2020 High Hampton submitted response to Corps. Part of that modification
request included reduction in stream and wetland impacts on Holes 1 and 9 already
authorized by the NC DWR 401. High Hampton was trying to further avoid stream and
wetland impacts and this effort included some redesign. Both the original design and the
modified design were based on flown topographic contours. However, once tree clearing
and grading activities began construction was difficult/impossible to match proposed
grades and contours with the existing topography. Hole 9 was intended to avoid wetland
# 28 and Stream #24 with a 2:1 graded slope. The as -built shows a vertical retaining
boulder wall. To complete the hole at the designed elevation and slopes this additional fill
was needed. This impact was based on unexpected inaccuracy from flown contours to
completed design information. The applicant proposes to mitigate for this additional 361f.
at a 2:1 ratio.
Construction of Hole 1 included installing the culvert in the dry. A parallel channel was
constructed in the dry for the new culvert. The contractor installed 2101f. of culvert in a
straight line, rather than following the meander of the stream. This resulted in 247 If. of
stream impact. Due to error in construction, 37 linear feet additional stream impacts
resulted. Please note, even with this error, the stream impacts associated with golf holes 1
and 9 are 135 If. less than was permitted by DWR on January 21, 2020. The applicant
DocuSign Envelope ID: C5722192-190B-4C6C-9866-6073E4050C94
Mr. Sue Homewood
March 5, 2021
Page 3 of 3
proposes to mitigate for this additional 37 If at a 2:1 ratio. The updated mitigation
summary is described below.
Hole 13
The contractor was confused by the modified April 6, 2020 revised trout buffer plan (Sheet
C-411). This plan shows the proposed grading contours and limits of the silt fence. The
contractor did not seek clarification of the plans and instead filled to the limits of the trout
buffer clearing also shown on this plan. This impact includes 39 linear feet of additional
impact. High Hampton propose to mitigate for this impact at a 2:1 ratio. The updated
mitigation summary is described below.
Mitigation
The updated stream and wetland mitigation table dated December 22, 2020 (attached) identified a
total of 92 linear feet of additional unauthorized stream impact throughout the project. In addition
to the three areas describe above there were some other minor changes reductions/additions, the
balance of which totals 921f of additional impact. High Hampton proposes to mitigate for all these
additional impacts at a 2:1 ratio.
As discussed at our site meeting with DWR and the Corps, additional mitigation was requested for
the remaining section of stream between Holes 1 and 9 where the sediment impacts to the stream
occurred. This length of stream totals approximately 80 If. High Hampton proposes to mitigate
for this section at a 0.5:1 ratio.
Thank you for reviewing the responses to agency comments above. Should you have any questions
or comments concerning this project please do not hesitate to contact me at 828-698-9800.
Sincerely,
1DocuSigned by:
2. CA--A2,J&
OA79F7DC85EE4F7...
R. Clement Riddle, P.W.S
Principal
Attachments:
Attachment A: Holes 1 & 9 Trout Buffer Variance Figure 405 9.24.18
Holes 1 & 9 Trout Buffer Variance Figure 405 revised 4.14.20
Holes 1 & 9 Impact As -Built Figure C-100 12.21.20
Attachment B: Impact As -built Tables
Copy Furnished:
NC Division of Water Resources, Asheville Regional Office — Kaylie Yankura
NC Division of Water Resources, Winston-Salem Office — Sue Homewood
WETLAND
IMPACT #24
0.006 AC
STREAM
IMPACT #22
247 LF
WETLAND
IMPACT #23
0.001 AC.
Imo,'
HOLE #1
GRAPHIC SCALE
IN FEET )
I•' 11�
I90
to
10
i
\ s
STREAM J
IMPACT #24
36 LF
STREAM
IMPACT #23
146 LF
WETLAND
IMPACT #25
0.014 AC.
WETLAND
IMPACT #26
0.006 AC.
SURVEYED
LIMITS OF
DISTURBANCE
(TYP)
WETLAND
IMPACT #28
0.011 AC.
LEGEND
CEC WETLAND
CEC STREAM
CEC CULVERT
CEC LINEAR WETLAND
SURVEYED LIMIT OF
DISTURBANCE
SURVEYED CULVERT
WETLAND IMPACT
STREAM IMPACT
HOLE #9
/ V 1. SURVEY INFORMATION
PROVIDED BY SYLVESTER &
COMPANY, P.A.
2. DELINEATION INFORMATION
PROVIDED BY CLEARWATER
ENVIRONMENTAL (SUBMETER
ACCURACY)
WGLA ENGINEERING, PLLC
724 5th AVENUE WEST
HENDERSONVILLE, NC 28739
(828)687-7177
WGLA.COM
NC LICENSE P-1342
High Hampton
Cashiers Township
Jackson County
North Carolina
0\0 11IIII/////
N C ARO
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Cg�StrutJpp
zI'1<<00AM0 00
REVISIONS
DATE DESCRIPTION
Im
Know what's below.
Call before you dig.
PROJECT NUMBER: 19159
DATE: 12/21/20
DRAWN BY: KHC
CHECKED BY: WRB
AB Stream & Wetland
Impact Maps
Hole 1 & 9
C-100
SCALE: 1 "=40'
Know what'sRSCALE:PROJECT NUMBER:DATE:DRAWN BY:CHECKED BY:WGLA ENGINEERING, PLLC724 5th Avenue WestHENDERSONVILLE, NC 28739(828) 687-7177WGLA.COMNC LICENSE P-1342High HamptonGolf CourseRenovation Jackson CountyNorth Carolina171829/18KHCWRBTrout BufferVariance PlansC-4051"=60'HOLE #9HOLE #1RSODocuSign Envelope ID: B1668C04-DEF8-406C-BA84-CA273A5FD7BC4/14/2020
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Table 1 and Table 2 provide an updated comprehensive list of proposed stream and wetland impacts for the project and As-Built impacts. This
information is also updated on the attached Stream and Wetland Impact Map (Revised December 22, 2020; Figure 5.0, Attached).
Table 1. Proposed Stream Impacts
Stream Impact Impact Type Proposed May 2018
Impact (LF)
Proposed June 18, 2019
Impact (LF)
Proposed March 23, 2020
Impact (LF)
As-Built
December 2020
Stream Impact #1 Golf 62 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Stream Impact #2 Golf 158 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Stream Impact #3 Golf 110 55 Eliminated - Redesign Eliminated - Redesign
Stream Impact #4 Golf 106 53 53 92
Stream Impact #4a Golf 0 0 12 20
Stream Impact #5 Road 46 Eliminated - Bridge Eliminated - Bridge Eliminated - Bridge
Stream Impact #6 Golf 269 Eliminated - Arch Culvert Eliminated - Arch Culvert Eliminated - Arch Culvert
Stream Impact #7 Road 68 68 68 (Phase 2) 59
Stream Impact #8 Road 30 30 30 (phase 2) Eliminated - Redesign
Stream Impact #9 Road 11 11 11 (phase 2) 7
Stream Impact #10 Road 66 66 66 (phase 2) 58
Stream Impact #11 Road 55 55 Eliminated - Redesign Eliminated - Redesign
Stream Impact #12 Road 45 Eliminated - Bridge Eliminated - Bridge Eliminated - Bridge
Stream Impact #13 Road 72 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Stream Impact #14 Golf (ATF)* 200 60 60 59
Stream Impact #15 Golf 142 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Stream Impact #16 Golf 119 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Stream Impact #17 Road 23 23 Eliminated - Redesign Eliminated - Redesign
Stream Impact #18 Road 50 Eliminated Bridge Eliminated Bridge Eliminated Bridge
Stream Impact #19 Golf 153 75 Eliminated - Redesign Eliminated - Redesign
Stream Impact #20 Golf 74 74 25 49
Stream Impact #21 Road 98 75 Eliminated - Redesign Eliminated - Redesign
Stream Impact #22 Golf 554 382 210 247
Stream Impact #23 Golf 146 146 146 146
Stream Impact #24 Golf 36 36 Eliminated - Redesign 36
Total Stream Impacts (Golf): 2,129 LF 881 LF 506 649
Total Stream Impacts (Road): 564 LF 373 LF 175 124
Total Stream Impacts 2,693 LF 1,209 LF 681 773
*ATF (after-the-fact)
Table 2. Proposed Wetland Impacts
Wetland Impact Impact
Type
Proposed Total Impact
May 30, 2018 (AC)
Proposed Total Impact June
18, 2019 (AC)
Proposed Total Impact March
23, 2020 (AC)
As-Built
December 2020
Wetland Impact #1 Golf 0.003 0.003 0.003 Eliminated - Redesign
Wetland Impact #2 Golf 0.008 0.008 0.008 Eliminated - Redesign
Wetland Impact #3 Golf 0.002 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Wetland Impact #4 Golf 0.022 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Wetland Impact #5 Golf 0.001 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Wetland Impact #6 Road 0.005 0.005 0.005 0.005
Wetland Impact #7 Road 0.001 0.001 0.001 Eliminated - Redesign
Wetland Impact #8 Road 0.044 0.044 Eliminated - Redesign Eliminated - Redesign
Wetland Impact #9 Golf (ATF)* 0.05 0.007 0.007 0.007
Wetland Impact #10 Golf 0.002 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Wetland Impact #11 Golf 0.065 0.065 0.065 0.001
Wetland Impact #12 Golf 0.076 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Wetland Impact #13 Golf 0.029 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Wetland Impact #14 Golf (ATF) 0.073 0.046 0.046 0.041
Wetland Impact #15 Golf (ATF) 0.011 0.011 0.011 0.011
Wetland Impact #16 Golf 0.004 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Wetland Impact #17 Road 0.005 0.005 Eliminated - Redesign Eliminated - Redesign
Wetland Impact #18 Road 0.006 0.006 0.006 0.006
Wetland Impact #19 Road 0.171 Eliminated - Redesign Eliminated - Redesign Eliminated - Redesign
Wetland Impact #20 Golf 0.098 0.098 0.098 0.075
Wetland Impact #21 Golf 0.039 0.039 0.039 0.006
Wetland Impact #22 Golf 0.004 0.004 0.004 0.003
Wetland Impact #23 Golf 0.001 0.001 0.001 0.001
Wetland Impact #24 Golf 0.006 0.006 0.006 0.006
Wetland Impact #25 Golf 0.014 0.014 0.014 0.014
Wetland Impact #26 Golf 0.006 0.006 Eliminated – Redesign 0.006
Wetland Impact #27 Golf 0.002 0.002 Eliminated – Redesign Eliminated - Redesign
Wetland Impact #28 Golf 0.012 0.012 Eliminated - Redesign 0.012
Wetland Impact #29 Golf (ATF) 0 0.008 0.008 0.014
Wetland Impact #30 Golf (ATF) 0 0.004 0.004 0.004
Total Wetland Impacts (Golf): 0.528 AC 0.334 AC 0.314 0.201
Total Wetland Impacts (Road): 0.232 AC 0.061 AC 0.012 0..011
Total Wetland Impacts: 0.76 AC 0.395 AC 0.326 0.212
*ATF (after-the-fact)
Mitigation
Per the Corps January 29, 2020 letter and Applicants February 19, 2020 acknowledgment, all mitigation (wetlands and streams) will
be at a 2:1 ratio. As discussed in our pre-application meeting on March 20, 2018 and permit application, the applicant will mitigate
for 113 linear feet of previous cumulative stream impacts (2002 NWP 14 - 50 lf; 2008 NWP 39 - 3 lf; 2009 NWP 29 60 lf).
As-Built Mitigation update
The applicant made payment to the NC Division of Mitigation Services (DMS) for stream and wetland mitigation on April 22, 2020.
DMS ID# MR-06901.
The applicant proposes to mitigate at a 2:1 ratio for 92 linear feet of stream associated with the after-the fact permit request and 0.5:1
ratio for 80 linear feet of stream associated with sediment impact. A request for 132 linear feet of mitigation has ben submitted to
NC DMS.