NC0021407_Environmental Assessment_20030702

NPDES DOCUHENT !;CANNING COVER !;IaEET
NPDES Permit:
NC0021407
Highlands WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Compliance
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
July 2, 2003
This document is printed on reuse paper - ignore any
content on the re rerse side

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
July 2, 2003
Mr. Mike Osborne, P.E.
W.K. Dickson & Co., Inc.
616 Colonnade Dr.
Charlotte, North Carolina 28205
AT7wA
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Additional Information Request
Highlands WWTP Environmental
Assessment (19 February 2003)
PER (Revised 16 May 2003)
NPDES No. NC0021407
Macon County
Dear Mr. Osborne:
The Division of Water Quality has reviewed the Town of Highlands Preliminary Engineering
Report (PER), Revised May 16, 2003. This document was referenced in the Town's Environmental
Assessment (EA) for the expansion of the plant to 1.5 MGD. Although many questions were clarified
with the PER, further questions must be addressed prior to agreeing with submittal of comments for a
Finding of No Significant Impact (FONSI).
1. Land -Based Disposal (spray or drip irrigation). Please follow the guidelines specified in the NPDES
Unit's Engineering Alternatives Analysis (EAA) Guidance document, attached, for determining soils
loading rates. For existing facilities, best -case loading rates for the documented soil types may be
used. Calculations should be shown to document the amount of land needed for spray or drip
irrigation. Land costs should be documented (this may be acquired from a Real Estate agent).
For spray irrigation, please document 1 MGD wastewater with storage (this assumes no increase in
a discharge permit from the existing 0.5 MGD permitted flow).
For drip irrigation - the same may be assumed. Land requirements will be somewhat less based
on the smaller buffer requirement.
Spray and drip irrigation do not have to meet the same treatment requirements as a discharging
system (they usually employ only stabilization and storage along with disinfection, therefore,
expansion of the wastewater treatment plant will likely not be necessary with these options).
For re -use of wastewater, stringent treatment is required and the wastewater treatment plant
would have to be expanded to comply with re -use rules.
2. Cost Estimations. The cost estimations for the various alternatives are well documented.
However, in instances where costs are estimated based on best professional judgement or previous
projects - please be certain that these can be fully substantiated, if necessary.
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 10% POST -CONSUMER PAPER
VISIT US ON THE WEB AT http://h2o.enr.state.nc.us/NPDES

Mr. Osborne
Page 2 of 2
Should you have further questions regarding the items above, please contact Susan A. Wilson,
P.E. at (919) 733 - 5083, ext. 510.
Sincerely,
Susan A. Wilson, P.E.
NPDES Unit
cc: Central Files
Alex Marks, Local Government Assistance Unit, Planning Branch
Asheville Regional Office, Water Quality Section
Mr. Gerald Pottem
Robert J. Goldstein and Associates, Inc.
8480 Garvey Dr.
Raleigh, NC 27616
Mr. Richard Betz, Town Administrator
Town of Highlands
P.O. Box 460
Highlands, North Carolina 28741
NPDES file

PERMIT NUMBER: NC0021407
FACILITY NAME: Town of Highlands - Highlands WWTP
CITY: Highlands
OUTFALL: 001
EFFLUENT
COUNTY: Macon
PERIOD ENDING MONTH: 5 - 2003
REGION: Asheville
DMR 12 Month Calculated
PAGE 1 OF 2
00010
deg c
Temperature,
Water Deg.
Centigrade
00300
mg/1
DO, Oxygen,
Dissolved
00310
mg/1
BOD, 5-Day (20
Deg. C)
00340
mg/1
COD, Oxygen
Demand, Chem.
(High Level)
00400
su
pH
00500
mg/1
Solids, Total
00530
mg/1
Solids, Total
Suspended
00545
ml/1
Solids,
Settleable
6 - 02
30
30
20.1
5.375
7.075
6.7 - 6.9
4.85
7 - 02
30
30
21.74
5.26
6.88
6.7 - 6.9
3.64
8 - 02
30
30
22.225
5.15
6.2
6.8 - 6.9
0.7
9 - 02
30
30
20.75
5.25
7.3
6.7 - 6.9
4.375
10-02
30
30
17.86
6.54
8.62
6.7 - 7
1.8
11 -02
30
30
12.125
6.575
8.45
6.7 - 7
10.475
12-02
30
30
7.82
7.18
6.04
6.8 - 7
3.6
1 - 03
30
30
4.475
7.925
6.125
6.8 - 7.1
2.15
2 - 03
30
30
5.725
7.35
8.2
6.8 - 7
13.25
3 - 43
30
30
9.7
6.75
9.55
6.7 - 6.9
2.45
4 - 03
30
30
12.42
6.68
12.52
6.9 - 7.1
3.62
5 - 03
30
30

PERMIT NUMBER: NC0021407
FACILITY NAME: Town of Highlands - Highlands WWTP
CITY: Highlands
COUNTY: Macon
PERIOD ENDING MONTH: 5 - 2003
REGION: Asheville
DMR 12 Month Calculated
PAGE 2 OF 2
00600
mg/1
Nitrogen, Total
(as N)
00610
mg/1
Nitrogen,
Ammonia Total
(as N)
00665
mg/1
Phosphorus,
Total (as P)
31616
#/100m1
Coliform, Fecal
MF, M-FC
Broth,44.5C
31616
mpn/100m1
Coliform, Fecal
MF, M-FC
Broth,44.5C
50050
mgd
Flow, in
conduit or thru
treatment plant
50060
mg/1
Chlorine, Total
Residual
50060
ug/1
Chlorine, Total
Residual
6-02
8.3
0.5
0.425
1
0.155233
0
7-02
8.3
0.5
0.86
0.82
0.63
1
0.179452
0
8-02
8.5
0.5
0.2
1
0.161968
0
9-02
8.3
0.5
0.325
1
0.199567
0
10-02
8.3
0.5
0.04
1
0.192323
0
11 -02
20
0.5
2.39
0.05
2.84
1
0.178133
0
12 - 02
20
0.5
0.46
1
0.167161
0
1 - 03
20
0.5
4.45
1
0.141613
0
2-03
20
0.5
0.725
1
0.144357
0
3 - 03
20
0.5
0.175
1
0.14871
0
4 - 03
8.3
0.5
2.84
0.22
1.78
1
0.1721
0
5-03
8.5
0.5
•

PERMIT NUMBER: NC0021407
FACILITY NAME: Town of Highlands - Highlands WWTP
CITY: Highlands
OUTFALL: 001
EFFLUENT
COUNTY: Macon
PERIOD ENDING MONTH: 12 - 2002
REGION: Asheville
DMR 12 Month Calculated
PAGE 1 OF 2
00010
deg c
Temperature,
Water Deg.
Centigrade
00300
mg/1
D0, Oxygen,
Dissolved
00310
mg/1
BOD, 5-Day (20
Deg. C)
00340
mg/1
COD, Oxygen
Demand, Chem.
(High Level)
00400
su
pH
00500
mg/1
Solids, Total
00530
mg/1
Solids, Total
Suspended
00545
ml/1
Solids,
Settleable
1 - 02
30
30
6.08
6.68
7.82
6.8 - 7
11.52
2 - 02
30
30
6.825
6.85
7.2
6.9 - 7
2.25
3-02
30
30
8.625
6.875
7.225
6.8 - 7.1
7.175
4 - 02
30
30
13.4
6.18
4.74
6.8 - 7
4.02
5 - 02
30
30
16.275
5.725
9.3
6.8 - 7
4.325
6 - 02
30
30
20.1
5.375
7.075
6.7 - 6.9
4.85
7 - 02
30
30
21.74
5.26
6.88
6.7 - 6.9
3.64
8 - 02
30
30
22.225
5.15
6.2
6.8 - 6.9
0.7
9 - 02
30
30
20.75
5.25
7.3
6.7 - 6.9
4.375
10 - 02
30
30
17.86 •
6.54
8.62
6.7 - 7
1.8
11 -02
30
30
12.125
6.575
8.45
6.7 - 7
10.475
12 - 02
30
30
7.82
7.18
6.04
6.8 - 7
3.6

PERMIT NUMBER: NC0021407
FACILITY NAME: Town of Highlands - Highlands WWTP
CITY: Highlands
COUNTY: Macon
PERIOD ENDING MONTH: 12 - 2002
REGION: Asheville
DMR 12 Month Calculated
PAGE 2 OF 2
00600
mg/1
Nitrogen, Total
(as N)
00610
mg/1
Nitrogen,
Ammonia Total
(as N)
00665
mg/1
Phosphorus,
Total (as P)
31616
#/100m1
Coliform, Fecal
MF, M-FC
Broth,44.5C
31616
mpn/100m1
Coliform, Fecal
MF, M-FC
Broth,44.5C
50050
mgd
Flow, in
conduit or thru
treatment plant
50060
mg/1
Chlorine, Total
Residual
50060
ug/1
Chlorine, Total
Residual
1 -02
20
0.5
3.66
1
0.137677
0
2 - 02
20
0.5
2.35
1
0.126107
0
3 - 02
20
0.5
2.325
1
0.143806
0
4 - 02
8.3
0.5
0.42
1
0.1553
0
5.02
8.5
0.5
0.25
1
0.161323
0
6-02
8.3
0.5
0.425
1
0.155233
0
7-02
8.3
0.5
0.86
0.82
0.63
1
0.179452
0
8-02
8.3
0.5
0.2
1
0.161968
0
9 - 02
8.5
0.5
0.325
1
0.199567
0
10 - 02
8.3
0.5
0.04
1
0.192323
0
11 - 02
20
0.5
2.39
0.05
2.84
1
0.178133
0
12.02
20
0.5
0.46
1
0.167161
0

Highlands Flow
Town of Highlands - High
NC0021407
50050 - Flow, in conduit or th
Month Day Year Comment Sample UoM Value Modife
1 1 2002 Estimate mgd .16
1 2 2002 Estimate mgd .129
1 3 2002 Estimate mgd .125
1 4 2002 Estimate mgd .113
1 5 2002 Estimate mgd .111
1 6 2002 Estimate mgd .108
1 7 2002 Estimate mgd .119
1 8 2002 Estimate mgd .13
1 9 2002 Estimate mgd .136
1 10 2002 Estimate mgd .113
1 11 2002 Estimate mgd .12
1 12 2002 Estimate mgd .176
1 13 2002 Estimate mgd .118
1 14 2002 Estimate mgd .09
1 15 2002 Estimate mgd .113
1 16 2002 Estimate mgd .109
1 17. 2002 Estimate mgd .097
1 18 2002 Estimate mgd .112
1 19 2002 Estimate mgd .118
1 20 2002 Estimate mgd .236
1 21 2002 Estimate mgd .135
1 22 2002 Estimate mgd .142
1 23 2002 Estimate mgd .155
1 24 2002 Estimate mgd .248
1 25 2002 Estimate mgd .227
1 26 2002 Estimate mgd .147
1 27 2002 Estimate mgd .132
1 28 2002 Estimate mgd .109
1 29 2002 Estimate mgd .168
1 30 2002 Estimate mgd .148
1 31 2002 Estimate mgd .124
2 1 2002 Estimate mgd .168
2 2 2002 Estimate mgd .138
2 3 2002 Estimate mgd .159
2 4 2002 Estimate mgd .121
2 5 2002 Estimate mgd .11
2 6 2002 Estimate mgd .115
2 7 2002 Estimate mgd 223
2 8 2002 Estimate mgd .137
2 9 2002 Estimate mgd .14
2 10 2002 Estimate mgd .112
2 11 2002 Estimate mgd .114
2 12 2002 Estimate mgd .113
2 13 2002 Estimate mgd .122
2 14 2002 Estimate mgd .106
2 15 2002 Estimate mgd .105
2 16 2002 Estimate mgd .132
2 17 2002 Estimate mgd .133
1

Highlands Flow
Month Day Year Comment Sample UoM Value Moditie
2 18 2002 Estimate mgd .121
2 19 2002 Estimate mgd .112
2 20 2002 Estimate mgd .131
2 21 2002 Estimate mgd .13
2 22 2002 Estimate mgd .126
2 23 2002 Estimate mgd .127
2 24 2002 Estimate mgd .108
2 25 2002 Estimate mgd .104
2 26 2002 Estimate mgd .115
2 27 2002 Estimate mgd .111
2 28 2002 Estimate mgd .098
3 1 2002 Estimate mgd .109
3 2 2002 Estimate mgd .119
3 3 2002 Estimate mgd . 71
3 4 2002 Estimate mgd .108
3 5 2002 Estimate mgd .132
3 6 2002 Estimate mgd .123
3 7 2002 Estimate mgd .132
3 8 2002 Estimate mgd .127
3 9 2002 Estimate mgd .136
3 10 2002 Estimate mgd .135
3 11 2002 Estimate mgd .106
3 12 2002 Estimate mgd .128
3 13 2002 Estimate mgd .169
3 14 2002 Estimate mgd .178
3 15 2002 Estimate mgd .144
3 16 2002 Estimate mgd .138
3 17 2002 Estimate mgd .142
3 18 2002 Estimate mgd .141
3 19 2002 Estimate mgd .14
3 20 2002 Estimate mgd .134
3 21 2002 Estimate mgd .154
3 22 2002 Estimate mgd .148
3 23 2002 Estimate mgd .136
3 24 2002 Estimate mgd .122
3 25 2002 Estimate mgd .121
3 26 2002 Estimate mgd .125
3 27 2002 Estimate mgd .21
3 28 2002 Estimate mgd .101
3 29 2002 Estimate mgd .159
3 30 2002 Estimate mgd .226
3 31 2002 Estimate mgd .144
4 1 2002 Recorder mgd .17
4 2 2002 Recorder mgd .14
4 3 2002 Recorder mgd .136
4 4 2002 Recorder mgd .132
4 5 2002 Recorder mgd .134
4 6 2002 Recorder mgd .152
4 7 2002 Recorder mgd .133
4 8 2002 Recorder mgd .114
4 9 2002 Recorder mgd .128
2

Highlands Flow
Month Day Year Comment Sample UoM Value Modifiie
4 10 2002 Recorder mgd .236
4 11 2002 Recorder mgd .173
4 12 2002 Recorder mgd .151
4 13 2002 Recorder mgd .172
4 14 2002 Recorder mgd .168
4 15 2002 Recorder mgd .159
4 16 2002 Recorder mgd .182
4 17 2002 Recorder mgd .174
4 18 2002 Recorder mgd .162
4 19 2002 Recorder mgd .166
4 20 2002 Recorder mgd .173
4 21 2002 Recorder mgd .165
4 22 2002 Recorder mgd .149
4 23 2002 Recorder mgd .146
4 24 2002 Recorder mgd .162
4 25 2002 Recorder mgd .153
4 26 2002 Recorder mgd .155
4 27 2002 Recorder mgd .142
4 28 2002 Recorder mgd .148
4 29 2002 Recorder mgd .145
4 30 2002 Recorder mgd .139
5 1 2002 Recorder mgd .154
5 2 2002 Recorder mgd .179
5 3 2002 Recorder mgd .172
5 4 2002 Recorder mgd .161
5 5 2002 Recorder mgd
5 6 2002 Recorder mgd .175
5 7 2002 Recorder mgd .207
5 8 2002 Recorder mgd .192
5 9 2002 Recorder mgd .19
5 10 2002 Recorder mgd .159
5 11 2002 Recorder mgd .166
5 12 2002 Recorder mgd .155
5 13 2002 Recorder mgd .147
5 14 2002 Recorder mgd .143
5 15 2002 Recorder mgd .148
5 16 2002 Recorder mgd .154
5 17 2002 Recorder mgd .137
5 18 2002 Recorder mgd .153
5 19 2002 Recorder mgd .155
5 20 2002 Recorder mgd .125
5 21 2002 Recorder mgd .121
5 22 2002 Recorder mgd .14
5 23 2002 Recorder mgd .159
5 24 2002 Recorder mgd .141
5 25 2002 Recorder mgd .141
5 26 2002 Recorder mgd .161
5 27 2002 Recorder mgd .156
5 28 2002 Recorder mgd .166
5 29 2002 Recorder mgd .158
5 30 2002 Recorder mgd .169
3

Highlands Flow
Month Day Year Comment Sample UoM Value Modifle
5 31 2002 Recorder mgd .166
6 1 2002 Recorder mgd .145
6 2 2002 Recorder mgd .144
6 3 2002 Recorder mgd .139
6 4 2002 Recorder mgd .144
6 5 2002 Recorder mgd .125
6 6 2002 Recorder mgd .151
6 7 2002 Recorder mgd .211
6 8 2002 Recorder mgd .165
6 9 2002 Recorder mgd .143
6 10 2002 Recorder mgd .136
6 11 2002 Recorder mgd .115
6 12 2002 Recorder mgd .156
6 13 2002 Recorder mgd .149
6 14 2002 Recorder mgd .161
6 15 2002 Recorder mgd .173
6 16 2002 Recorder mgd .145
6 17 2002 Recorder mgd .115
6 18 2002 Recorder mgd .128
6 19... 2002 Recorder mgd .161
6 20 2002 Recorder mgd .15
6 21 2002 Recorder mgd .155
6 22 2002 Recorder mgd .148
6 23 2002 Recorder mgd .152
6 24 2002 Recorder mgd .158
6 25 2002 Recorder mgd .163
6 26 2002 Recorder mgd t1-4-i7
6 27 2002 Recorder mgd 1L.-191
6 28 2002 Recorder mgd .176
6 29 2002 Recorder mgd .143
6 30 2002 Recorder mgd .168
7 1 2002 Recorder mgd .16
7 2 2002 Recorder mgd .152
7 3 2002 Recorder mgd .178
7 4 2002 Recorder mgd .232
7 5 2002 Recorder mgd .188
7 6 2002 Recorder mgd .21
7 7 2002 Recorder mgd .183
7 8 2002 Recorder mgd .151
7 9 2002 Recorder mgd .156
7 10 2002 Recorder mgd .145
7 11 2002 Recorder mgd .162
7 12 2002 Recorder mgd .177
7 13 2002 Recorder mgd .229
7 14 2002 Recorder mgd .217
7 15 2002 Recorder mgd .184
7 16 2002 Recorder mgd .166
7 17 2002 Recorder mgd .202
7 18 2002 Recorder mgd .162
7 19 2002 Recorder mgd .178
7 20 2002 Recorder mgd .183
4

4
Highlands Flow
Month Day Year Comment Sample UoM Value Modifle
7 21 2002 Recorder mgd .166
7 22 2002 Recorder mgd .16
7 23 2002 Recorder mgd .177
7 24 2002 Recorder mgd .178
7 25 2002 Recorder mgd .194
7 26 2002 Recorder mgd .192
7 27 2002 Recorder mgd .184
7 28 2002 Recorder mgd .183
7 29 2002 Recorder mgd .171
7 30 2002 Recorder mgd .166
7 31 2002 Recorder mgd .177
8 1 2002 Recorder mgd .171
8 2 2002 Recorder mgd .176
8 3 2002 Recorder mgd .171
8 4 2002 Recorder mgd .166
8 5 2002 Recorder mgd .152
8 6 2002 Recorder mgd .169
8 7 2002 Recorder mgd .168
8 8 2002 Recorder mgd .142
8 9 2002 Recorder mgd .118
8 10 2002 Recorder mgd .143
8 11 2002 Recorder mgd .211
8 12 2002 Recorder mgd .168
8 13 2002 Recorder mgd .144
8 14 2002 Recorder mgd .154
8 15 2002 Recorder mgd .182
8 16 2002 Recorder mgd .148
8 17 2002 Recorder mgd .149
8 18 2002 Recorder mgd .16
8 19 2002 Recorder mgd .136
8 20 2002 Recorder mgd .145
8 21 2002 Recorder mgd .138
8 22 2002 Recorder mgd .16
8 23 2002 Recorder mgd .148
8 24 2002 Recorder mgd .157
8 25 2002 Recorder mgd .179
8 26 2002 Recorder mgd .157
8 27 2002 Recorder mgd .166
8 28 2002 Recorder mgd .191
8 29 2002 Recorder mgd .173
8 30 2002 Recorder mgd .164
8 31 2002 Recorder mgd 215
9 1 2002 Recorder mgd .164
9 2 2002 Recorder mgd .162
9 3 2002 Recorder mgd .16
9 4 2002 Recorder mgd .159
9 5 2002 Recorder mgd .123
9 6 2002 Recorder mgd .132
9 7 2002 Recorder mgd .16
9 8 2002 Recorder mgd .133
9 9 2002 Recorder mgd .116
5

Highlands Flow
Month Day Year Comment Sample UoM Value Modifie
9 10 2002 Recorder mgd .116
9 11 2002 Recorder mgd .114
9 12 2002 Recorder mgd .119
9 13 2002 Recorder mgd .138
9 14 2002 Recorder mgd .163
9 15 2002 Recorder mgd .263
9 16 2002 Recorder mgd .327
9 17 2002 Recorder mgd .162
9 18 2002 Recorder mgd .231
9 19 2002 Recorder mgd .163
9 20 2002 Recorder mgd .159
9 21 2002 Recorder mgd .211
9 22 2002 Recorder mgd .299
9 23 2002 Recorder mgd .211
9 24 2002 Recorder mgd .133
9 25 2002 Recorder mgd .187
9 26 2002 Recorder mgd .215
9 27 2002 Recorder mgd .407
9 28 2002 Recorder mgd
9 29 2002 Recorder mgd .386
9 30 2002 Recorder mgd .2225�
10 1 2002 Recorder mgd .218
10 2 2002 Recorder mgd .178
10 3 2002 Recorder mgd .183
10 4 2002 Recorder mgd .218
10 5 2002 Recorder mgd .213
10 6 2002 Recorder mgd .197
10 7 2002 Recorder mgd .159
10 8 2002 Recorder mgd .169
10 9 2002 Recorder mgd .172
10 10 2002 Recorder mgd .162
10 11 2002 Recorder mgd .164
10 12 2002 Recorder mgd .203
10 13 2002 Recorder mgd .218
10 14 2002 Recorder mgd .175
10 15 2002 Recorder mgd .168
10 16 2002 Recorder mgd .292
10 17 2002 Recorder mgd .237
10 18 2002 Recorder mgd .206
10 19 2002 Recorder mgd .21
10 20 2002 Recorder mgd .21
10 21 2002 Recorder mgd .194
10 22 2002 Recorder mgd .178
10 23 2002 Recorder mgd .162
10 24 2002 Recorder mgd .2
10 25 2002 Recorder mgd .176
10 26 2002 Recorder mgd .189
10 27 2002 Recorder mgd .187
10 28 2002 Recorder mgd .167
10 29 2002 Recorder mgd .193
10 30 2002 Recorder mgd .19
6

Highlands Flow
Month Day Year Comment Sample UoM Value Module
10 31 2002 Recorder mgd .174
11 1 2002 Recorder mgd .17
11 2 2002 Recorder mgd .207
11 3 2002 Recorder mgd .188
11 4 2002 Recorder mgd .186
11 5 2002 Recorder mgd .171
11 6 2002 Recorder mgd .176
11 7 2002 Recorder mgd .17
11 8 2002 Recorder mgd .153
11 9 2002 Recorder mgd .168
11 10 2002 Recorder mgd .215
11 11 2002 Recorder mgd .205
11 12 2002 Recorder mgd .233
11 13 2002 Recorder mgd .209
11 14 2002 Recorder mgd .173
11 15 2002 Recorder mgd .157
11 16 2002 Recorder mgd .222
11 17 2002 Recorder mgd .279
11 18 2002 Recorder mgd .176
11 19 2002 Recorder mgd .167
11 20 2002 Recorder mgd .163
11 21 2002 Recorder mgd .167
11 22 2002 Recorder mgd .184
11 23 2002 Recorder mgd .177
11 24 2002 Recorder mgd .156
11 25 2002 Recorder mgd .135
11 26 2002 Recorder mgd .143
11 27 2002 Recorder mgd .146
11 28 2002 Recorder mgd .141
11 29 2002 Recorder mgd .147
11 30 2002 Recorder mgd .16
12 1 2002 Recorder mgd .187
12 2 2002 Recorder mgd .138
12 3 2002 Recorder mgd .122
12 4 2002 Recorder mgd .141
12 5 2002 Recorder mgd .147
12 6 2002 Recorder mgd .246
12 7 2002 Recorder mgd .155
12 8 2002 Recorder mgd .15
12 9 2002 Recorder mgd .137
12 10 2002 Recorder mgd .133
12 11 2002 Recorder mgd .157
12 12 2002 Recorder mgd .174
12 13 2002 Recorder mgd .142
12 14 2002 Recorder mgd .165
12 15 2002 Recorder mgd .186
12 16 2002 Recorder mgd .138
12 17 2002 Recorder mgd .119
12 18 2002 Recorder mgd .144
12 19 2002 Recorder mgd .14
12 20 2002 Recorder mgd 1..,.24 1
7

Highlands Flow
Month Day Year Comment Sample UoM Vatue Modifie
12 21 2002 Recorder mgd .224
12 22 2002 Recorder mgd .172
12 23 2002 Recorder mgd .142
12 24 2002 Recorder mgd .143
12 25 2002 Recorder mgd .33
12 26 2002 Recorder mgd .136
12 27 2002 Recorder mgd .161
12 28 2002 Recorder mgd .191
12 29 2002 Recorder mgd .178
12 30 2002 Recorder mgd .161
12 31 2002 Recorder mgd .169
1 1 2003 Recorder mgd 246
1 2 2003 Recorder mgd .209
1 3 2003 Recorder mgd .157
1 4 2003 Recorder mgd .196
1 5 2003 Recorder mgd .169
1 6 2003 Recorder mgd .14
1 7 2003 Recorder mgd .144
1 8 2003 Recorder mgd .139
1 9 2003 Recorder mgd .148
1 10 2003 Recorder mgd .148
1 11 2003 Recorder mgd .138
1 12 2003 Recorder mgd .125
1 13 2003 Recorder mgd .099
1 14 2003 Recorder mgd .134
1 15 2003 Recorder mgd .124
1 16 2003 Recorder mgd .122
1 17 2003 Recorder mgd .119
1 18 2003 Recorder mgd .115
1 19 2003 Recorder mgd .13
1 20 2003 Recorder mgd .125
1 21 2003 Recorder mgd .129
1 22 2003 Recorder mgd .14
1 23 2003 Recorder mgd .133
1 24 2003 Recorder mgd .128
1 25 2003 Recorder mgd .14
1 26 2003 Recorder mgd .121
1 27 2003 Recorder mgd .123
1 28 2003 Recorder mgd .12
1 29 2003 Recorder mgd .124
1 30 2003 Recorder mgd .152
1 31 2003 Recorder mgd .153
2 1 2003 Recorder mgd .14
2 2 2003 Recorder mgd .123
2 3 2003 Recorder mgd .094
2 4 2003 Recorder mgd .123
2 5 2003 Recorder mgd .138
2 6 2003 Recorder mgd .127
2 7 2003 Recorder mgd .126
2 8 2003 Recorder mgd .14
2 9 2003 Recorder mgd .112
8

4
Highlands Flow
Month Day Year Comment Sample UoM Value Modtfie
2 10 2003 Recorder mgd .099
2 11 2003 Recorder mgd .128
2 12 2003 Recorder mgd .106
2 13 2003 Recorder mgd .119
2 14 2003 Recorder mgd .119
2 15 2003 Recorder mgd .138
2 16 2003 Recorder mgd .167
2 17 2003 Recorder mgd .207
2 18 2003 Recorder mgd .159
2 19 2003 Recorder mgd .157
2 20 2003 Recorder mgd .134
2 21 2003 Recorder mgd .131
2 22 2003 Recorder mgd .366
2 23 2003 Recorder mgd .143
2 24 2003 Recorder mgd .129
2 25 2003 Recorder mgd .155
2 26 2003 Recorder mgd .16
2 27 2003 Recorder mgd .171
2 28 2003 Recorder mgd .131
3 1 2003 Recorder mgd .156
3 2 2003 Recorder mgd .152
3 3 2003 Recorder mgd .13
3 4 2003 Recorder mgd .129
3 5 2003 Recorder mgd .133
3 6 2003 Recorder mgd .139
3 7 2003 Recorder mgd .189
3 8 2003 Recorder mgd .15
3 9 2003 Recorder mgd .132
3 10 2003 Recorder mgd .116
3 11 2003 Recorder mgd .116
3 12 2003 Recorder mgd .127
3 13 2003 Recorder mgd .127
3 14 2003 Recorder mgd .128
3 15 2003 Recorder mgd .135
3 16 2003 Recorder mgd .129
3 17 2003 Recorder mgd .147
3 18 2003 Recorder mgd .143
3 19 2003 Recorder mgd .152
3 20 2003 Recorder mgd 252
3 21 2003 Recorder mgd .28
3 22 2003 Recorder mgd .171
3 23 2003 Recorder mgd .153
3 24 2003 Recorder mgd .133
3 25 2003 Recorder mgd .131
3 26 2003 Recorder mgd .144
3 27 2003 Recorder mgd .144
3 28 2003 Recorder mgd .16
3 29 2003 Recorder mgd .153
3 30 2003 Recorder mgd .13
3 31 2003 Recorder mgd .129
4 1 2003 Recorder mgd .129
9

Highlands Flow
Month Day Year Comment Sample UoM Value Modifie
4 2 2003 Recorder mgd .137
4 3 2003 Recorder mgd .155
4 4 2003 Recorder mgd .132
4 5 2003 Recorder mgd .137
4 6 2003 Recorder mgd .155
4 7 2003 Recorder mgd .131
4 8 2003 Recorder mgd .269
4 9 2003 Recorder mgd .175
4 10 2003 Recorder mgd .192
4 11 2003 Recorder mgd .194
4 12 2003 Recorder mgd .193
4 13 2003 Recorder mgd .16
4 14 2003 Recorder mgd .12
4 15 2003 Recorder mgd .162
4 16 2003 Recorder mgd .148
4 17 2003 Recorder mgd .176
4 18 2003 Recorder mgd .186
4 19 2003 Recorder mgd i .283
4 20 2003 Recorder mgd .169
4 21 2003 Recorder mgd .174
4 22 2003 Recorder mgd .197
4 23 2003 Recorder mgd .184
4 24 2003 Recorder mgd .164
4 25 2003 Recorder mgd .158
4 26 2003 Recorder mgd .185
4 27 2003 Recorder mgd .17
4 28 2003 Recorder mgd .151
4 29 2003 Recorder mgd .21
4 30 2003 Recorder mgd .167
10

North Carolina Wildlife Resources Commission
Charles R. Fullwood, Executive Director
MEMORANDUM
TO: J. Todd Kennedy, Environmental Coordinator
Division of Water Quality
FROM: Shannon Deaton, Manager
Habitat Conservation Section
DATE: April 11, 2003
SUBJECT: Revised Environmental Assessment for Town of Highlands WWTP, Macon
County, North Carolina
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have
reviewed the subject document. These comments are provided in accordance with certain
provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et
seq.), the North Carolina Statutes (G.S. 113-131 et seq.), and the National Environmental Policy
Act (42 U.S.C. 4332(2)(c)).
The revised environmental assessment (EA) provides additional information on the
conveyance system that was not included in the draft EA and provides clarification of the issues
that we rose during our initial review. We appreciate the attention to detail, organization and
thoroughness of the document.
We believe overall that the impacts of this project will be relatively positive, especially
for aquatic resources downstream within the Cullasaja River. The new wastewater treatment
plant will employ tertiary treatment resulting in a decrease in total mass loading for BOD,
nitrogen, phosphorus and residual chlorine even though the capacity of the plant is tripling. The
conversion from chlorination/dechlorination disinfection to ultraviolet disinfection is particularly
important in protecting aquatic resources downstream of wastewater treatment plants. The plant
expansion will allow for the retirement of several poorly functioning package plants and will
provide opportunities to eliminate individual septic systems. The elimination of these systems
has the potential to improve water quality within other streams within the Highlands area.
Our major concern with this expansion has been the impacts associated with secondary
and cumulative impacts of development within the Highlands area. The Highlands area drains to
two of the most important watersheds within the region. Most of the service area flows to the
Little Tennessee River via the Cullasaja River and its tributaries and is within a protected
watershed. Approximately, 25% of the service area drains to the Savannah River via the
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] ext. 281 • Fax: [phone]

Revised EA,Town of Highlands WWTP 2 April 11, 2003
Macon County, Cullasaja & Chattooga Rivers
Chattooga River and its tributaries. The Chattooga River drainage area consists of many streams
that support trout and some that are considered Outstanding Resource Waters. The streams in
this watershed have no buffer protection other than the minimal provided by the Division of
Land Quality trout buffer rules. Although the 25-foot buffer is beneficial, it is often not adequate
to protect aquatic life, due to insufficient width and variances that can be obtained for impact to
this buffer.
This project is designed primarily to serve existing development within the Town of
Highlands but proposes service to some annexation areas. The annexation areas include existing
residences as well as platted lots. We agree that the secondary and cumulative impacts resulting
from new sewers should be minimal for most of the service area and should be offset by the
positive impacts of elimination of failing septic systems and elimination of package plants.
However, new construction will add secondary and cumulative impacts to the respective
drainages. We are especially concerned about the development impacts within the Chattooga
River basin since these areas have significantly less protection than the water supply watersheds.
Additionally, the water supply rules do not address intermittent streams or perennial streams that
do not appear on USGS 7.5-minute topographic maps.
The Town of Highlands has some good proactive ordinances that have the potential to
minimize a number of secondary and cumulative impacts resulting from development. A pond -
draining ordinance serves to raise awareness about the importance of minimizing sedimentation
to downstream waters and provides fines for violation of the ordinance. A relatively new zoning
amendment requires that applicants applying for a Zoning Certificate must have a 404 permit for
wetland impacts prior to obtaining the Zoning Certificate. This has potential positive benefits by
increasing awareness of wetlands and permits needed. We are also pleased with the ordinances
that provide for cluster development if density requirements for the parcel are not exceeded. The
non -developed areas must be retained in open space. Highlands also regulates disturbances that
are greater than 3,000-square feet. This is especially important since the potential for
sedimentation in the Highlands' area is significant due to topography and high annual rainfall.
We realize that much of Highlands was built out before current rules; thus, the developed
areas that result in stormwater impacts are not easily addressed and would continue regardless of
expansion. We strongly encourage the Town of Highlands to continue to be proactive in
downtown areas by looking for opportunities to retrofit stormwater best management practices
(e.g., rain gardens, eliminate curb and gutter and storm drain sediment traps). We also encourage
Highlands to continue to look for opportunities to restore forested buffers along streams where
they are lacking.
The revised EA has addressed all the issues adequately except secondary and cumulative
impacts. Given the existing development within the Highlands area and the protection afforded
by watershed protection rules within the Little Tennessee River basin and local ordinances, we
believe the secondary and cumulative impacts have been minimized to a certain degree. We do
believe that buffer protection should be afforded to all perennial streams and to intermittent
streams within this drainage. In our opinion, the Chattooga watershed portion of the service area
is vulnerable because it lacks many of the safeguards of the water supply area and has no buffer
protection except the minimal afforded by the trout buffer rules. To protect the important
resources within the Chattooga River watershed, we recommend that the Town of Highlands
adopt an overlay for this service area that requires density limitations and buffer protection rules.
The NCWRC can concur with a Finding of No Significant Impact for this project
provided the project sponsor commits to the following:
1. Expand buffer protection rules within the Little Tennessee River portion of the watershed
to include all perennial streams not just those appearing on a USGS 7.5 minute Quad.

Revised EA,Town of Highlands WWTP 3 April 11, 2003
Macon County, Cullasaja & Chattooga Rivers
2. Expand buffer protection to include intermittent streams within the Little Tennessee
River portion of the watershed.
3. Adopt an overlay district for the service areas within the Chattooga River drainage that is
at least as restrictive as the water supply critical area of the Little Tennessee portion of
the watershed. The ordinance should include the density restrictions and buffer width
requirements. All perennial and intermittent streams should be required to have buffers.
The entire ordinance should apply to all new construction. Buffer rules should apply on
all stream buffers that have not been previously impacted regardless of existing
residences.
4. The NCWRC recommendations for secondary and cumulative impacts would be adopted
outside the proposed annexation areas for any new development being annexed and/or
served by the wastewater treatment plant.
Thank you for the opportunity to provide input into this project review. If you need
further information on these comments, please contact Owen Anderson at 828-452-2546 ext 24.
cc: Brian Cole, Supervising Biologist, USFWS
Steve Hall, Zoologist, NC Natural Heritage Program

DIVISION OF WATER QUALITY
March 25, 2003
To: Alex Marks
Local Government Assistance Unit
From: Susan A. Wilson, Environmental Engineer
NPDES Unit
Subject: Town of Highlands WWTP, Environmental Assessment
NPDES No. NC0021407
Macon County
I have reviewed portions of the Environmental Assessment (EA) for the proposed
increase in wastewater capacity for the Town of Highlands. The proposed project
includes the expansion of the wastewater treatment plant from 0.5 MGD to 1.5 MGD to
meet future growth needs around the Highlands area. The NPDES Unit submitted
comments on the first draft of the EA on October 1, 2002.
The consulting firm stated that the Preliminary Engineering Report (PER) addressed
many of the concerns brought forward in the memo from the NPDES Unit.
Unfortunately, the NPDES Unit has not seen the PER and reviews the EA as a
freestanding document. If the PER is to be referenced in the EA, it should be provided
for review (at least to the NPDES Unit, if not to the general public). We hope that the
PER thoroughly addresses the concerns expressed in the memo. The NPDES Unit
brings up the concerns in order to help expedite the permitting process. The issues
expressed in the memo must be addressed within the permit application, if they are not
addressed in the EA.
One of the items mentioned in the memo stated that operational conditions of existing
on -site systems be addressed in the document. The consulting firm stated that the
DENR office in Asheville would likely have that information. This answer is not
adequate - the consulting firm should provide a general statement from the County
Health Department stating the percentage of on -site septic systems, within the
proposed service area, which may be failing.
Another item mentioned in the October 2002 memo, was with regard to existing
developments and current methods of wastewater disposal. Again, this was not
adequately addressed in the response (and the NPDES Unit is unaware if this comment
was more adequately addressed in the PER). This should be addressed in the permit
application, if not the EA. This information must be provided as part of the flow
justification for the expansion request. A letter of intent to connect from the annexation
areas should be provided with the permit application (for those development areas with
discharge or non -discharge systems). This office is unaware that those areas may want
to connect to a regional system.

As with all new or expanding permits for wastewater, an engineering alternative
analysis (EAA) of options other than direct discharge should be addressed. An
application for a permit will not be accepted unless this is completed. Highland's
consultants should refer to the NPDES Unit's website under the documents section to
obtain a copy of the requirements for the EAA (ref. http://h2o.enr.state.nc.us/
NPDES/NPDESweb.html). Although not required to be presented as part of the EA,
addressing alternatives to discharge within the EA process will likely help expedite the
permitting process.
cc: Central Files
NPDES Files
ARO/ Water Quality Section

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DIVISION OF WATER QUALITY
March 25, 2003
To: Alex Marks
Local Government Assistance Unit
From: Susan A. Wilson, Environmental Engineer
NPDES Unit
Subject: Town of Highlands WWTP, Environmental Assessment
NPDES No. NC0021407
Macon County
I have reviewed portions of the Environmental Assessment (EA) for the proposed
increase in wastewater capacity for the Town of Highlands. The proposed project
includes the expansion of the wastewater treatment plant from 0.5 MGD to 1.5 MGD to
meet future growth needs around the Highlands area. The NPDES Unit submitted
comments on the first draft of the EA on October 1, 2002.
The consulting firm stated that the Preliminary Engineering Report (PER) addressed
many of the concerns brought forward in the memo from the NPDES Unit.
Unfortunately, the NPDES Unit has not seen the PER and reviews the EA as a
freestanding document. If the PER is to be referenced in the EA, it should be provided
for review (at least to the NPDES Unit, if not to the general public) . We hope that the
PER thoroughly addresses the concerns expressed in the memo. The NPDES Unit
brings up the concerns in order to help expedite the permitting process. The issues
expressed in the memo must be addressed within the permit application, if they are not
addressed in the EA.
One of the items mentioned in the memo stated that operational conditions of existing
on -site systems be addressed in the document. The consulting firm stated that the
DENR office in Asheville would likely have that information. This answer is not
adequate - the consulting firm should provide a general statement from the County
Health Department stating the percentage of on -site septic systems, within the
proposed service area, which may be failing.
Another item mentioned in the October 2002 memo, was with regard to existing
developments and current methods of wastewater disposal. Again, this was not
adequately addressed in the response (and the NPDES Unit is unaware if this comment
was more adequately addressed in the PER). This should be addressed in the permit
application, if not the EA. This information must be provided as part of the flow
justification for the expansion request. A letter of intent to connect from the annexation
areas should be provided with the permit application (for those development areas with
discharge or non -discharge systems). This office is unaware that those areas may want
to connect to a regional system.

As with all new or expanding permits for wastewater, an engineering alternative
analysis (EAA) of options other than direct discharge should be addressed. An
application for a permit will not be accepted unless this is completed. Highland's
consultants should refer to the NPDES Unit's website under the documents section to
obtain a copy of the requirements for the EAA (ref. http://h2o.enr.state.nc.us/
NPDES/NPDESweb.html). Although not required to be presented as part of the EA,
addressing alternatives to discharge within the EA process will likely help expedite the
permitting process.
cc: Central Files
NPDES Files
ARO/ Water Quality Section

TOWN OF HIGHLANDS
HIGHLANDS, NORTH CAROLINA
April 17, 2003
Division of Water Quality
NPDES Unit
ATTN: Susan A. Wilson
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Town of Highlands
Wastewater Treatment Plant
NPDES No. NC0021407
Dear Ms. Wilson:
I am writing in response to your memorandum of
March 25, 2003, concerning the Town of Highlands
Wastewater Treatment Plant project. The letter
requested additional information on (1) the operational
condition of existing on -site systems, and (2) existing
development and current methods of wastewater disposal
in annexation areas.
Condition of Existing On -site Systems
It is well -documented that the soil types in the
Highlands area, like most of the mountainous region of
Western North Carolina, are not conducive to on -site
septic systems. The problem is a critical one because,
of the 2600 current water customers in Town, only 580
(22%) are served by municipal sewer. Residential areas
immediately outside of Town which are being considered
for annexation are served by either on -site septic
systems or, in the case of a portion of Highlands Falls
Country Club, a small "package" treatment plant.
The Town's 1989 Land Use Plan (copy attached)
stated that "approximately 80% of the land area has a
soil type with a severe rating for septic field
absorption." It recommended as one of the strategies
to be pursued over the next 20 years that the Town
"seek elimination of all inadequate on -site sewage
treatment systems and place priority on providing sewer
service within the watersheds, particularly to
properties around Mirror Lake and Lake Sequoyah."
Studies by various consulting engineers have
confirmed the problems with existing on -site systems.
The 1989 Master Sewer Study (copy attached), prepared
(CONTINUED)
P.O. BOX 460 • HIGHLANDS, NORTH CAROLINA 28741 • [phone] • [phone] • FAX [phone]
Printed on Recycled Paper

Page Two
Letter to DWQ
April 17, 2003
by W. K Dickson Company, said that "a significant
number of septic tank installations are malfunctioning
or do not comply with today's more stringent standards,
thereby posing'a threat to water quality." A 1999 10-
Year Needs Assessment Study by W. K. Dickson (copy
attached) identified five specific areas to be
considered for possible annexation and provided cost
estimates for providing sewer service. A Macon County
Waster & Sewer Management Strategy (copy attached),
prepared in May of 2000 by Martin -McGill, referenced
this report. "Septic systems," it said, "exhibit a
high rate of failure in the mountains due to soil
types."
Instances of failing septic systems have been a
concern of the Macon County Health Department for a
number of years. A violation at a multi -family
residence on NC-106 required the Health Department to
take court action requiring periodic pumping of the
septic system; the violation was finally corrected when
the Town extended its municipal sewer line along NC-106
in 2001. A letter has been written (copy attached)
from the Macon County Health Department documenting the
general inadequacy of on -site septic systems.
Small "package" treatment plants have also proven
to be unreliable in the Highlands area due to the lack
of adequate operational procedures required for
municipal plants. The Town has eliminated several of
these sewer plants over the past 15 years and connected
them to the municipal sewer system. A plant operated
by S. B. Association, for example, was cited for
violations numerous times (copy of letter from DWQ
attached), and was finally connected to the municipal
system in November of 2002 when its NPDES permit
expired; it was the last package treatment plant in the
corporate limits to be connected.
Existing development Annexation Areas
The areas being considered for annexation
were specifically identified in a 1999 10-Year Needs
Assessment Study by W. K. Dickson (see above). The
largest of these areas is Highlands Falls Country Club;
the other areas are smaller residential areas that are
not part of a property owners association. The method
(CONTINUED)

Page Three
Letter to DWQ
April 1.7, 2003
of wastewater disposal consists of on -site septic
systems, and, in the case of a portion of Highlands
Falls Country Club, a small "package" treatment plant.
Town officials met on July 10, 2000, with
officials from Highlands Falls Country Club to discuss
the Town's annexation policies with respect to
extension of both water and sewer service. Town
officials met again on August 29, 2000, with officials
from Highlands Falls, and also the Upper Cullasaja
Watershed Association, Highlands -Cashiers Hospital,
Cullasaja Club, and Wildcat Cliffs Country Club to
discuss the same subject.
Ongoing discussions are proceeding, and the areas.
do meet the criteria for annexation; in fact, the
Division of Community Assistance has agreed to proceed
with a full annexation study. A letter of intent to
connect has not yet been submitted, however, nor would
it be feasible at this time. Federal and State funds
for such a project appear to be limited during the
current funding cycle, and the Town is facing
significant demands on its capital reserves over the
next two years, including funding of the proposed
Wastewater Treatment Plant expansion now estimated at
$4,908,000.
We hope that these comments and additional
information have been helpful in addressed the concerns
of the NPDES Unit. We would welcome the opportunity of
further discussing it with you.
Sincerely yours,
Richard Betz
Town Administrator
/rpb
cc: Alex Marks, AICP
Mayor Allen L. Trott
W. K. Dickson Company
Goldstein & Associates

NATURAL ENVIRONMENT
Volumes of facts and study materials could be prepared
attesting to the unique qualities of the Highlands natural
environment. It is truly an area of magnificent beauty and
unusual attraction. While all of this information is important,
certain facts have been highlighted in support of the strategies
contained in this section. This information generally falls into
three interrelated categories:
• Soils and soil structure
• Water quality and hydrology
• Wildlife and ecology
Soils and soil structure are aspects of the environment that
are most frequently overlooked and taken for granted. They are,
however, resources of immeasurable value, and are the telling
factors of not only ecological richness, but also constraints to
growth. With careful planning, a developed environment can
coexist with the natural environment. If proper care is not
taken, the developed environment can continue, but it will do so
• at the expense of resource ecology. A careful examination of the
soils found in the Highlands Township reveals that thex_are
generally very fragile, and very susc paible to erosion when
dilsturbea. More specifically, approximately 80% of the land area
hash soil t e with a severe ratan for se tic field absorption.
• Less an 2 of the land area is ideally suited for all types of
development. Almost 46% of the soils have an exceptionally high
rate of erodability when disturbed or not properly maintained.
These same soil types present severe limitations on the
construction of roads and buildings due to their structure.
Soil scientists have determined that, under normal
conditions, nature will create one inch of topsoil every 500
years in a typical deciduous forest environment. The soil
conditions in the Highlands area are more extreme than average,
and this rate of creation is probably much longer. More
importantly, the sensitivity to soil loss is significantly
greater and requires a correspondingly greater amount of care as
development occurs.
The second major environmental consideration is water and
the region's hydrology. With the exception of the Pacific
Northwest, Highlands has one of the highest annual rainfalls in
the country, averaging 84.9 inches. The abundance of this
resource is in evidence everywhere, and a relationship can easily
be drawn to the area's lush vegetation and diverse ecology. Even
though 60% of the Highlands Township's classified waters are
suitable for trout propagation, there are reasons to be concerned
about the continued quality of this resource. First, there is a
significant sedimentation problem that is adversely impacting the
area's waterways. An indication of this problem is the absence
5

of water lilies from impounded water bodies. A more in-depth
examination of the sedimentation problem would reveal other
effects on plant and animal species. Second, the drinking water
supply of the Town comes from the Cullasaja River and Big Creek
watersheds. These two watersheds yield water of high quality,
but their continued development could jeopardize this resource.
Stormwater runoff, increased sedimentation from development,
poorly -functioning septic tanks, and activities common to land
management such as the use of lawn chemicals, can all effect the
drinking water supply and water quality in general.
The third major environmental consideration is the area's
wildlife and ecology. At the present time, the limited amount of
biological data indicates that the Township is exceptionally
diverse. There are documented sightings of many rare and
endangered plants and animals, and many species found only in
distant parts of the hemisphere. The explanation for this
phenomenon is that, during the last ice age, the higher
elevations served as a refuge for all wildlife. After the ice
retreated, most species were able to re-establish themselves
throughout the continent. However, some species were left in
isolated pockets and were unable to proliferate. Highlands is
one of these "special areas," and continues to be an important
environment because of its topography, wild climate, and
plentiful water supply.
In light of this information, the following Mission
Statement and related strategies are designed to squarely address
the issue of protecting environmental quality:
MISSION STATEMENT: Maintain or improve the present quality of
the natural environment.
IMPLEMENTATION STRATEGIES:
• Strategy 1: Implement a general environmental program that
will work to improve conditions throughout the community. This
program includes the following elements:
A. Review the requirements of the North Carolina Ridge Law
and assume responsibility for its implementation within the
Community's jurisdiction. (7 - Planning Board; due 6/90; update
every 5 years.)
B. Implement standards that will effectively protect trees
and the vegetative character of the community. (8 - Planning
Board; due 6/90; update every 3 years.)
C. Support the preparation of a natural areas inventory
for the Township, and efforts to protect the resources identified
in this inventory. (9 - Planning Board; due 6/91; cost estimate
6

$14,000; no update.)
D. Encourage and support community programs of resource
conservation, wildlife protection, and environmental education.
This includes, for example, efforts such as trash recycling, the
peregrine falcon release program, etc. (10 - Planning Board; due
6/90; special appropriation; annual update.)
E. Acknowledge and appreciate the efforts of the F.A.C.E.
program, and other groups that work to improve the quality of the
community's general environment. (11 - Town Board; due 6/90;
special appropriation; annual update.)
F. Require that an Environmental Impact Assessment be
submitted for all disturbed land areas greater than one acre as
part of the development process. The criteria for the assessment
shall be developed by the Town and incorporated in the Zoning
permitting process. (12 - Planning Board; due 6/90; review
within 3 years and update every 5 years thereafter.)
G. Develop and periodically review emergency procedures
for the control of hazardous substances accidentally spilled
along the Community's roadways. (13 - Planning Board; due 6/91;
update every 5 years.)
H. Exercise a one -mile extraterritorial planning
jurisdiction, and extend zoning and subdivision regulations
within this area. (14 - Town Board; due 12/89.)
• Strategy 2: Implement a drinking water supply/watershed
management program that will effectively support a WS-II water
quality classification. This program includes the following
elements:
A. Define and officially designate the Cullasaja River and
the Big Creek watersheds as the drinking water supply sources for
the Town. (15 - Planning Board; due 12/89.)
B. Seek special enabling legislation from the North
Carolina General Assembly to extend the extraterritorial planning
authority throughout sections of the officially recognized
watershed that lie beyond the one -mile limit. (16 - Town Board;
due 6/91.)
C. Incorporate stormwater run-off controls in the Zoning
Ordinance that would require:
(1) all new development to retain the water run-off of
a ten-year storm (2.8 inches in one hour) on site for at least 24
hours; and
7

(2) all new development to channel run-off through
vegetated infiltration areas, detention/retention basins, etc.,
prior to entry into any creek, stream, or water body.
(17 - Planning Board; due 6/90; review within 3 years and update
every 5 years thereafter.)
D. Establish performance standards for all areas
immediately adjacent to creeks, streams, and water bodies,
requiring
(1) maintenance of a vegetated buffer;
(2) strict sedimentation and erosion control
provisions; and
(3) prohibition of impervious surfaces (subject to a
conditional use permit).
(18 - Planning Board; due 6/90; review within 3 years and update
every 5 years thereafter.)
E. Establish a two -acre minimum lot size in the designated
watersheds, with a "grandfather" provision for previously
subdivided lots. (19 - Planning Board; due 6/90; review within 3
years and update every 5 years thereafter.)
F. Contact all property owners within the watersheds, and
inform them that their property is within an environmentally
sensitive area and that the Town will assist those planning to
develop their property to consider watershed protection. (20 -
Planning Board; due 9/90; update every 5 years.)
G. Seek elimination of all inadequate on -site sewage
treatment, systems and place priority on providing sewer service
within the watersheds, particularly to properties around Mirror
Lake and Lake Sequoyah. (21 - Town Board; due 6/91; cost
unknown; ongoing ettort . )
H. Examine all existing stormwater outfalls within the
watersheds to determine if modification could be made to reduce
the amount of stormwater run-off by redirecting it into
woodlands, infiltration basins, or other areas. (22 - Planning
Board; due 12/91; cost unknown; ongoing effort.)
I. Petition the North Carolina Environmental Management
Commission to upgrade the water classification of the watersheds
after the Town has implemented the preceding strategies. (23 -
Planning Board; due 9/91.)
J. Periodically assess drinking water quality and quantity
to determine if additional action is needed to protect these
8

resources. (24 - Planning Board; due 9/90; cost unknown; update
every 2 years.)
• Strategy 3: Implement a general water quality program that
will work to improve conditions throughout the Community. This
program includes the following elements:
A. Sponsor a cooperative effort between the Town, the
North Carolina Agricultural Extension Service, and the golf
associations within the planning jurisdiction to improve the
selection and use of fairway chemicals. (25 - Planning Board;
due 12/90; update every 5 years.)
B. Sponsor biannual educational programs for the Community
to encourage proper use and disposal of chemicals used in and
around the home. (26 - Planning Board; due 6/91; update every 2
years.)
• Strategy 4: Implement a general land quality program that will
work to improve the conditions throughout the community. This
program includes the following elements:
A. Improved seeding and landscaping of utility rights -of -
way. (27 - Appearance Commission; due 12/90; cost unknown;
review within 3 years and update every 5 years thereafter.)
B. Identify areas with steep slopes, where improper
development could result in increased erosion and sedimentation.
Develop appropriate standards to reduce density and environmental
impact in these areas. (28 - Planning Board; due 6/90; update
every 5 years.)
9

TOWN OF HIGHLANDS
MASTER SEWER STUDY
PREPARED FOR
HIGHLANDS BOARD OF COMMISSIONERS
TOWN CLERK
HERBERT JAMES
JOHN CLEAVELAND, MAYOR
NED BRYSON
DONNIE CALLOWAY
LIGON CRESWELL
STEPHEN PIERSON
RON SANDERS
TOWN ATTORNEY
JACK MAYER
PREPARED BY:
W. K. DICKSON & COMPANY, INC.
ENGINEERS - PLANNERS*- SURVEYORS
1924 CLEVELAND AVENUE
CHARLOTTE, NORTH CAROLINA 28203
52 EAST MAIN STREET
SYLVA, NORTH CAROLINA 28779

W.K.
DIcKsoN ENGINEERS
PLANNERS
5 Co
■ INC. SURVEYORS
1924 CLEVELAND AVE
CHARLOTTE, NC 28203
704.334.5348
June 7, 1989
Mr. Herbert James
Town Clerk
Town of Highlands
Post Office Box 460
Highlands, North Carolina 28741
Re: Master Sewer Study
Dear Mr. James:
W. K. Dickson' .& Company, Inc., is pleased to present this
Master Sewer Study to the Town of Highlands. This study
identifies a long term plan of capital improvements to provide
sanitary sewer service to the Town of Highlands over the next
twenty (20) years.
We wish to express our appreciation for this opportunity we
have had in providing these services to the Town and look forward
to working with you in the future.
Sincerely,
W. K. DICKSON & CO., INC.
•David L. Pond, P. E.
Senior Vice President
Pate.e
Paul R. White, P. E.
DLP/sls
Enclosure

STUDY AREAS
The Town limits was divided into seven study areas to more
accurately define the problems, limitations and needs of each
area. The boundaries were selected_to delineate areas with
similar, easily describable characteristics. The prominent
characteristics of each study area including zoning, housing
density, lot sizes and terrain were considered. Different growth
factors were assigned to determine population growth and
wastewater loadings for each study area. Figure 5 shows the
study area boundaries.
Study Area No. 1: •
Area 1 is bounded on the north by the Town limits from
Highway 64 to the divide between Mirror Lake and Big Creek. It
is bounded on the east and south by Highway 64, and on the west
by the divide between Mirror Lake and Big Creek. This area
includes the lower Mill Creek drainage and Mirror Lake. Area 1
contains approximately 432 acres and 323 water connections.
This area includes the Town's wastewater treatment plant.
The plant effluent is discharged into Mill Creek, which flows
into Mirror Lake. This area is zoned primarily medium density
residential. It has 323 water billings, yet only 7 sewer
connections, 5 of these being commercial. Based on knowledge of
the area an, previous experience,, it is reasonable to assume that
a signifyant number of septic tank installations are
malfuncting or do notcomply with today's more stringent
standards, thereby posing a threat to water quality.
-17-

Town of Highlands
Water & Sewer Facilities
10 Year Needs Assessment Study
December 14, 1999
Draft Copy for Review and Comment
• For:
Town of Highlands
Post Office Box 460
Highlands, NC 28741
Prepared by:
WK Dickson
1419 Patton Avenue
Asheville, NC 28806
828-251-1610
•
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III. GROWTH PROJECTIONS
POPULATION
Population projection in the Town of Highlands for the purpose of estimating future
water and sewer needs has been divided into two groups. The first is the • existing
populace, which includes permanent residents, seasonal residents, and- transient
visitors. The second group is the additional permanent and seasonal residents, added
through annexation.
Group I
Permanent Residents
US Census data for the year 1990 showed the population in the corporate limits
to be 948 people. US Census data for the year 1997 showed the population in
the corporate limits to be 1,071 people. This reflects a uniform 1.85% growth
rate per year over those seven years. It is important to note that no annexation
occurred during this period. Projecting a 1.85% per year uniform growth rate
from 1997 to 1999, produces an estimated permanent population in the city limits
of approximately 1,111 people. At the estimated growth rate of 1.85% per year
from 1999 to the year 2010, the projected permanent population will be
approximately 1,337 people
Seasonal Residents
For the purpose of this study, the seasonal population and growth rate has been
determined by comparing the percentage of increase in residential water meters
read between the years 1988 and 1997. A density of two (2) people per
residential meter was assumed.
According to the Town of Highlands' records, there were approximately 1,762
residential water meters in 1988, and 2510 residential meters in 1999. This
represents a 3.86% uniform growth rate per year in residential water meters.
9 WKD #90582.40

Assuming two (2) people per residential water meter, the 1999 seasonal and
permanent residents can be estimated at approximately 5,020. Subtracting the
projected 1999 permanent population of 1,111 people from the estimated total
population of 5,020 yields an estimated 1999 seasonal population_. of
approximately 3909 people.
With residential water meter installations increasing at a uniform rate of 3.86%
per year, and permanent population growing at a uniform rate of 1.85% per year,
it can be estimated that seasonal population is growing at a approximate rate of
2.01%.
Assuming the projected 1999 population of permanent residents of 1,111 and a
growth rate of 1.85% per year, the estimated population of permanent residents
for the Town of Highlands in the year 2010. will be 1,337. Projecting the
calculated year 1999 seasonal resident population of 3,910 at a growth rate of
2.01 % per year, the estimated year 2010 population of seasonal residents is
4,774. Total anticipated peak seasonal population for the Town of Highlands in
the year 2010 would be approximately 6,111 people.
Transients
Transients, unlike daily visitors, are defined as. people who spend more than a
day in Highlands and occupy the available motel/hotel rooms in the area. The
Highlands Chamber of Commerce estimates there are 450 hotel/motel rooms
available. Based on double occupancy, the peak transient population would be
900 people. Land zoned for hotel/motel use is limited; the percentage increase
in this population would seem to be small in comparison and therefore, for the
purposes of this report is assumed to remain a constant.
10 WKD #90582.40

Total Estimated Peak Population for Year 2010
The total estimated peak population as a result of normal growth, within the current
Town limits, to the year 2010 will be approximately 7011 people, including 900
transients. _
Group II
Population Increases Through Annexation
For the purposes of this report, it is assumed that the corporate limits of the Town
of Highlands will expanded to include all areas under consideration for
annexation, and an 80% residential build out will occur in these areas.
The areas under consideration for annexation may be defined as follows:
A-1. North Area including Hicks Road, Billy Cabin Road, Zachary Road
A-2. Highland Falls Country Club
A-3. South of NC 106, including the Ponderosa Subdivision
A-4. _ North of NC 106, including Mountain Laurel and Dog Mountain
Subdivision
A-5. Flat Mountain Area
Within these areas, there are approximately 677 parcels including those Tots with
existing homes. Almost half of these Tots are within the Highland Falls Country
Club. An 80% build out of residential dwellings with two (2) people per home
would add 1,084 people to the Town's population. The makeup of permanent
and seasonal residents that will occupy all these homes is not known. This will
require an additional 542 water service connections to be considered for peak
water and sewer demand forecasting.
11 WKD #90582.40

Population Projection Summary
Population projections 'through the year 2010 including normal growth and areas
currently under consideration for annexation indicate a population of
approximately 8,095 people.
Population projections through the year 2010, excluding any annexation, indicate
a peak population of 7,011 people.
ANNEXATION AREAS (see capital improvements plan for cost breakdown)
A-1
North Annexation Area
The North Annexation area is West of highway 64 to Billy Cabin and
Zachary Roads, and areas around Hicks Road. This area contains
approximately 360 acres. The total perimeter of this area is approximately
22,488 feet, and 39% of that is contiguous with the existing City limits.
There are approximately 144 existing residences and 79 vacant Tots in this
area. Assuming an 80% build out, an additional 178 water and sewer
services need to be planned for. Estimated cost to provide city water
service to this area is estimated at $1,764,100. Estimated cost to provide
city sewer service to this area is $1,182,000
A-2 Highlands Falls Annexation Area
The Highland Falls Country Club area contains approximately 540 acres.
The. total area perimeter contains approximately 38,314 feet, and 37% of
that is contiguous with the existing city limits. There are approximately 300
lots in this area. Assuming an 80%.build out, an additional 240 water and
sewer services should be planned for.
One problem associated with the annexation of Highlands Falls is the
possible duplication of water and sewer services. A public utility company
operates the water and sewer systems, within Highland Falls. If the Town
12 WKD #90582.40

were to annex this area, and the utility company wanted to continue to
operate their water and sewer systems, the town would have to install
parallel lines. And in doing that, there would be no guarantee that the
homeowners would switch their services over to the town. If the town were
to purchase the existing water system, the majority of it would have to be
replaced to provide fire protection, as the largest lines in the system are
only 4 inch. For the purposes of this report, it is assumed that the existing
distribution system would be replaced to provide fire protection
A similar problem exists with the wastewater collection and treatment
system. There is no guarantee that the public utility would want to sell its
collection system or its wastewater treatment plant. For the purposes of
this report, it is assumed that the existing waste water treatment plant
would be replaced with a pump station; the existing collection system in
Highland Falls would continue to be utilized
Estimated Cost to provide. City water service to this area is $2,906,670.
Estimated cost to Provide City Sewer Service to this area is $848,166. •
A-3 NC 106 South
Highway 106 South, including the Ponderosa Subdivision. This area
contains approximately 85 acres. The perimeter is approximately 12,513
feet long, of which approximately 6,382 feet (0.51%) is contiguous with the
existing City Limits. There are approximately 25 existing residences and 25
vacant lots in this area. Estimated cost to provide city water to this area is
$406,640. Estimated cost to provide city sewer service to this area is
$295, 555.
13 WKD #90582.40

A-4 NC 106 North
NC 106 North, including Mountain Laurel and Dog Mountain Subdivisions.
This area contains approximately 107 acres. The perimeter is
approximately 14,596 feet long, of which 2,602 feet (18%) is contiguous
with the existing City Limits. There are approximately 46 existing
residences and 38 'vacant Tots in this area. Estimated costs to provide City
water service to this area is $224,250. Estimated cost to provide city sewer
service to this area is $443,322.
A-5 Flat Mountain Area.
Flat Mountain. This area contains approximately 42 acres. The perimeter is
approximately 9,300 feet long, of which approximately 1,959 feet (21%) is
contiguous with the existing City Limits. There are approximately 22
existing residences and 2 vacant lots in this area. Estimated cost to provide
City water service to this area is $171,925. Estimated Cost to provide City
sewer service to this area is $325,111.
14 WKD #90582.40

• 1
'1
1
l
7
1
1
TECHNICAL ASSESSMENT OF WATER AND SEWER
INFRASTRUCTURE
Macon County is the fastest growing county in. Western .North Carolina and the 13th
fastest growing in North Carolina. The population. increase from 1990 to 2000 is
estimated at 24.6 % . This is causing major development pressure and a high demand
for water and sewer services throughout the County.
The need to expand systems, especially to areas outside municipal boundaries, is
exacerbated by potential negative environmental impacts of the - County's current
growth. The Town of Franklin's wastewater treatment system is facing a state -imposed
moratorium on future connections unless existing failing trunk lines are replaced.
Currently, these old terra cotta lines are failing along the Little Tennessee River
creating a threat to the river. Therefore, the Town is under pressure to address this
public health need. At the same time, the Town of Highlands needs an alternative
water source to accommodate growth. However, the two primary potential surface
water sources are contaminated by non -point source pollution -from failing septic
systems located nearby. The Town needs to provide sewer service to this area in order
to enhance these potential water sources. In addition, the rapidly growing summer and
second home industry is largely dependent upon in -ground septic systems. Septic
systems exhibit a high rate of failure in the mountains due to o_ f soil types. The
negative effect of these failing septic systems can be combined with the effects of
domestic waste "straight piping" which is the disposal method in apEroximately 25% of
the homes in the County. .
The principal elements of this technical assessment include the following:
• Evaluate historical trends of population growth, development and
water/sewer use.
• Prepare projections of future population as well as commercial and industrial
growth along with the associated water and sewer needs.
• Review existing water supply, treatment, transmission, distribution, pumping
and storage facilities.
• Review existing sewage collection, pumping and treatment facilities.
5/11/00 W&S PLAN REPORT-rcv08AC.doc 3

MACON COUNTY PUBLIC HEALTH CENTER
"The Heart of Prevention"
1830 Lakeside Drive ♦ Franklin, NC 28734
Phone [phone] • FAX [phone]
April 16, 2003
Richard Betz, Town Administrator
Town of Highlands
Post Office Box 460
Highlands, North Carolina 28741
Dear Mr. Betz:
I am writing about the wastewater plant expansion for the Town of Highlands. I support
your town in expanding the wastewater plant.
In general most properties in and around Highlands are not conducive for private on -site
wastewater (septic) systems. Soil types in your area and shallow, and bedrock is 0 — 36
inches. In recent years our Environmental Health staff have only been able to give
provisional approval for Highlands properties in over 90% of the systems.
Our department has a concern about failed septic systems in Highlands. Each month our
Environmental Health Sections receives approximately three (3) applications to repair
septic systems or reports on failed septic systems in the Highlands area. This relates
largely to the soil types in Highlands. In addition the steep terrain in the area poses a
challenge for on -site wastewater systems.
Many of the existing Highlands homes, built several years ago for weekend or vacation
homes, are now being occupied on a full-time basis. In several cases the original septic
systems were designed too small for the current residents.
Because of all the reasons stated above, I support the expansion of the Highlands
Wastewater Plant. Should you have any questions, please contact me.
Sincerely,
Kenneth D. Ring, MPH
Health Director

Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Kerr T. Stevens, Director
Division of Water Quality
Asheville Regional Office
• WATER QUALITY SECTION
May 18, 2001
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Creighton W. Sossomon
S. B. Association
P.O. Box 9 .
Highlands, North Carolina 28741-0009
Subject: NOTICE OF VIOLATION and
RECOMMENDATION for ENFORCEMENT
Failure to Report a Wastewater Spill and
North Carolina General Statutes
Article 21 A, Part I, Section 143-215.1
Macon County
Dear Mr. Sossomon:
Mr. Kevin Barnett of my staff visited the S. B. Association wastewater treatment plant on May 2nd, 2001
in response to a verbal report of a spill of untreated wastewater reaching surface waters which was
reported to the Division of Water Quality on May 2001.
The following violations are noted:
• NPDES permit number. NC0058262, Section E. 6. a. requires that the permittee submit a written
report of such non-compliance within 5 days. This notice of non-compliance must include a
description of the spill, an estimate if the duration of the spill, the volume of wastewater spilled, the
volume of wastewater reaching surface waters, and a description of any corrective actions taken.
No report of non-compliance has been received at this office.
• North Carolina General Statute Article 21 A, Part I, Section 143-215.1 (1) requires that a
permit be issued for "outlets to waters of the state." The discharge of raw sewage from S. B.
Association to Monger Creek between Club Lake and Lake Sequoyah is considered to be "making
an outlet to waters of the state."
Fecal Coliform samples taken at the site of discharge are as follows:
Upstream: 2 / 100 mis •
Downstream: 13,000 / 100 mis
• NPDES permit number NC0058262, Supplement to Permit Cover Sheet (2.) authorizes S. B.
Association to discharge treated wastewater into Lake Sequoyah. This treatment plant is currently
. discharging its wastewater onto the hillside above Monger creek.
irSzA
NCDENR
Water Ouality Section. 59 Woodfin Place. Asheville. NC 28801-2414 Teleohane: 828/251-6208 Customer Service •

NOTICE OF VIOLATION and RECOMMENDATION for ENFORCEMENT Page 2..
S. B. Association
The following items must be addressed:
• A written spill report must be inailed to the Asheville Regional Office of the Division of Water
Quality immediately, upon receipt of this Notice.
• All residual solids from the spill must be cleaned up and the area limed to minimize impact from
disease carrying vectors. Care must be taken to ensure that lime is not introduced into the creek.
Additionally, the fence surrounding the wastewater treatment plant must be repaired where it was
removed during the stopping of the spill. •
• S. B. Association must apply to the Division of Water Quality to modify it's permit to reflect the
change of discharge from Lake Sequoyah to Monger creek.
• The discharge pipe must be extended to surface waters in order to eliminate the discharge of treated
wastewater to the land surface.
If you have an explanation for these violations that you wish to present, please respond in writing to me
within ten (10) days following receipt of this Notice. Your explanation will be reviewed and if an
enforcement action is still deemed appropriate, your explanation will be given due consideration when
civil penalties are assessed.
If you have any question, do not hesitate to contact Kevin Barnett'of my staff at 828-251-6208 ext. 205.
Sincerely,
orrest R. Westall, P.E.
Water Quality Regional Supervisor
cc: Macon County Health Dept
Mark Teague, Environmental Maintenance Systems
Town of Highlands
Point Source Compliin e / Enforcement Unit

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Association to monitor on -site development activities such as proper use of silt fencing and the
qualifications of heavy equipment operators under the Clean Water Contractor Program.
Coordination with Macon County: In response to water quality degradation originating
outside Town limits, the Town officially requested that Macon County enforce a local Soil Erosion
and Sedimentation Ordinance (similar to its own Ordinance adopted in 1984) and an Ordinance
Regulating the Draining of Impoundments (similar to the groundbreaking Ordinance developed by
the Town and adopted March 7, 2002) in the Lake Sequoyah Watershed outside the corporate
limits. Both Ordinances have been adopted and are being enforced (in addition to the County
Watershed Protection Ordinance adopted in 1994). The Soil Erosion Ordinance was adopted in
November of 2001. The Impoundment Ordinance was adopted July 1, 2002, and the interlocal
agreement providing for enforcement by the Town Watershed Administrator was approved July 3.
Natural Areas Inventory: The need for a Natural Areas Inventory was identified as a key
component of the Town's 1989 Land Use Plan. The inventory was conducted by Dr. L. L. Gaddy
with support from the N. C. Natural Heritage Foundation, and was completed in May 1992. This
document identifies areas on the Highlands Plateau with significant biological or geological
features that should be protected. It is used by the Highlands Land Trust, a private nonprofit
corporation dedicated to the acquisition and protection of significant lands, and by Highlands and
Macon County in planning for growth and review of development plans. To date none of the
significant natural areas identified in the survey in Highlands has been developed.
Greenways: The Highlands greenway was developed in 1991 as a walking
and educational trail, stretching from the Mirror Lake wetlands on the Mill Creek arm of the lake
southeastward through the downtown area to the summit of Sunset Rock in southeastern
Highlands. The trail segment which parallels Mill Creek through the Town's 30 acre Recreation
Park is left primarily in its natural state.
7.0. STATE AND FEDERAL PERMITS REQUIRED
• SEPA Environmental Assessment (EA) review and concurrence with a Finding of No
Significant Impact (FONSI) is required.
• An Air Emissions Permit from DAQ may be required for emergency back-up generators at the
WWTP, depending on fuel type and power rating.
• The DENR Regional Office, Land Quality Supervisor must approve an Erosion and
Sedimentation Control Plan.
• The Highlands WWTP NPDES discharge permit will need to be revised and re -issued by NC-
DWQ to reflect the new effluent limits and discharge volume.
29

Impoundments greater than one-half acre in size or having a drainage basin larger than
75 acres must have a plan prepared by a NC Professional Engineer and submitted for
impoundment draining permit approval. The plan must include a time schedule of proposed
activities, erosion control structures, diversion measures, and other protection mechanisms to
reduce the receiving water's susceptibility to sedimentation and erosion up to the ten-year storm
event. If the drainage is to be permanent, measures to stabilize areas subject to erosion and
sedimentation must be incorporated. Methods to achieve turbidity below 50 NTUs in all receiving
waters must be included.
The watershed administrator may solicit comments on the permit proposal from the Town
Engineer, other qualified professionals, or the NC DENR, and request post -construction turbidity
monitoring from the same. In addition to the impoundment draining permit, applicants are
required to comply with all state and federal regulations. The penalty for violating this ordinance
is $50,000.
6.2.5. Lake Ordinance and Reservoir Recreation Plan.
Lake Sequoyah was reclassified to a Class 1 Public Water Supply Reservoir in 2000,
culminating the Town's seven year effort to remove all point source discharges in the watershed.
The last remaining package WWTP (S.B. Associates Plant) is scheduled to be retired and
connected to the Town's sewage collection system by 30 November 2002. A Lake Ordinance
and Reservoir Recreation Plan were adopted in October 1999 as part of the reclassification
process.
The Lake Ordinance requires a 50 foot vegetated buffer around the lake shoreline, nearly
all of which is private land. The buffer area should maintain diffuse flow so that runoff does not
become channelized. Existing private boat docks may be repaired, but no new or expanded
structures are allowed. Materials used for repair may include untreated wood, plastic, or
concrete. Creosote or pressure -treated wood are prohibited. Fishing and boating are allowed on
most of the lake, but boats are limited to a maximum speed of five miles per hour, and electric
motors are recommended. No boating is allowed within a 50 yard radius ofthe water supply
intake on the Big Creek arm of Lake Sequoyah. The ordinance prohibits spitting, urinating,
defecating, or placing any liquids, solids, or trash (except as authorized by the ordinance) in the
lake or its environs (which includes the 50 foot buffer and other areas from which runoff may
enter the lake). No domestic animals are allowed in the lake or within 50 feet of the shoreline.
No open fires are allowed along the lake shoreline or at the lake's public access facilities. No
firearms, alcoholic beverages, or hunting is allowed in the environs of the lake. The operator of
any boat on the lake is responsible for preventing passengers from violating this ordinance, and
failure to do so, whether intentional or by neglect, shall constitute a violation. Any person
convivcted of violating any provision of this ordinance shall be fined $500 and/or imprisoned for
30 days.
6.2.6. Other Water Quality Protection Measures.
In addition to the Water Supply Watershed Ordinance, Soil Erosion and Sedimentation
Control Ordinance, Zoning and Subdivision Ordinances discussed above, the Town of Highlands
uses some non -regulatory measures and incentives to provide additional protection of stream
channel integrity and water quality. The town works closely with the Upper Cullasaja Watershed
28

(EMC's) 25-foot buffers adjacent to waters designated as Trout waters and further requires that
all buffers with Tr be wide enough to confine visible siltation to within the landward (edge closest
to land disturbance) 25 percent of the buffer width.
Erosion and sedimentation control devices, either manmade or natural, must be sufficient
to protect surface waters from siltation and runoff from the calculated 10-year storm. Exposed
slopes shall be gradual enough to restrain accelerated erosion and must be revegetated within 30
working days of project completion. Land disturbing activities within HQW zones must not disturb
more than 20 acres at any one time. Erosion and sedimentation control devices installed for
disturbances in HQW zones must be designed to accommodate for the calculated 25-year storm,
and sediment basins must have a settling efficiency of at least 70 percent of the 40 micron soil
particles. Areas of land disturbance in HQW zones must be provided with ground cover sufficient
to restrain erosion within 15 working or 60 calendar days, whichever is shorter.
Section 1116 of the Ordinance addresses required permits for land disturbances of any
size. Activities such as driveway construction, septic tank installation, fire fighting activities, etc.
are exempted from this requirement. In most cases, the applicability of this requirement will be
decided by the Zoning Administrator.
In October 2001 the Soil Erosion Control ordinance was amended to strengthen protection
on steep slopes: The application for a Land Disturbing Permit shall identify the total area to be
disturbed and the greatest slope within the disturbed area. The Zoning Administrator may
conduct an inspection to verify the slope with an appropriate mreasuring device. The new
requirements are:
(1) 0 to 30% Slope: A site plan shall be submitted, drawn to a scale of at least one inch in forty
feet, and indicating the nature and location of all land disturbing activities proposed for the site
that may cause or contribute to soil erosion and sedimentation, together with those measures and
devices intended to control soil erosion and sedimentation.
(2) 30 to 60% Slope: In addition to the information required for slopes of 0-30%, topographic
contour lines shall be indicated on the site plan at a minimum of five foot intervals, and a detailed
planting schedule for each phase of construction shall be submitted.
(3) Over 60% Slope: A full erosion and sedimentation control plan shall be submitted, pursuant to
Section 1117 of this Ordinance, regardless of the area to be disturbed."
6.2.4. Ordinance Regulating the Draining of Impoundments.
On 07 March 2002, the Town of Highlands adopted an ordinance regulating the draining
of impoundments within the town's corporate limits (Section 2). Pursuant to the rules, individuals
wishing to drain an impoundment must first apply for, and receive, an Impoundment Draining
Permit.
Impoundments one-half acre or smaller in size and having a drainage basin less than 75
acres must submit a plan indicating the proposed method of dewatering and indicate measures to
prevent sediment from being released to receiving waters. The plan must include a time
schedule of proposed activities. If the drainage is to be permanent, measures to stabilize areas
subject to erosion and sedimentation must be incorporated. Methods to achieve turbidity below
50 NTUs in all receiving waters must be i ,eluded.
27

water distribution systems must be approved by the appropriate state agencies or Macon or
Jackson County health departments. These systems must also be reviewed by the Town
Engineer or an approved representative thereof, and a report submitted to the Town prior to its
review.
Parcels subject to adverse environmental or topographic constraints that pose a threat to
health, safety, or property must have said adverse conditions corrected prior to approval by the
Town. Water and sewer systems that shall connect to the public system must be designed and
sealed by a PE. Where public water systems are utilized, hydrants must be served by a minimum
pipe diameter of six inches. Where a private sewer and water system is to be utilized, the Macon
or Jackson County Health Department shall conduct field investigations of the proposed system
and provide the developer with a letter of approval for the system.
All rules and design specifications set forth in the Town's Zoning Ordinance shall be
enforced during the subdivision review process. However, the minimum lot size requirement may
be waived in the case of cluster developments. Cluster developments are exempt from minimum
lot size requirements, but will not exceed the maximum number of lots allowed in a particular
zoning district and must utilize extraordinary water control measures such as bioreactive ponds or
subsurface drainage reservoirs. The reduction in lot size achieved by a cluster development
must be compensated for by dedication of an equal amount of open space. The open space may
be granted to the Town or retained privately. Open space must be maintained and preserved in
perpetuity. The open space dedicated or preserved must, to the extent practicable, incorporate
existing significant natural features.
New stormwater conveyances lying parallel to new or existing roads must be designed to
effectively convey the calculated 10-year storm flows. Cross drainages, which cross
perpendicular to new or existing roads, must be designed to effectively convey the calculated 25-
year storm flows. In the event that a natural stream channel must be relocated, the resulting
channel must be capable of effectively carrying the calculated 100-year storm flow.
Any land proposed for subdivision which lies, in whole or part, in the watershed of any
water designated as a water supply, shall conform to the standards set forth in the NC Water
Supply Watershed Protection Act (G.S. 214.5, or House Bill 156).
6.2.3. Soil Erosion and Sedimentation Control Ordinance
Highlands adopted a Soil Erosion and Sedimentation Control Ordinance, Chapter 11 of
the Town Code, on 07 October 1992. The ordinance regulates land -disturbing activities within
the Town and its ETJ (essentially the entire proposed wastewater service area) with respect to
erosion and sedimentation control. The Town's Zoning Administrator is responsible for erosion
and sedimentation control plan review, permit issuance, and enforcement.
The Ordinance mandates that all land disturbing activities that impact more than 3,000 ft2.
must first obtain a sedimentation and erosion control permit. Erosion and sedimentation control
plans must identify environmentally sensitive areas subject to greater erosion and sedimentation
control risks and limit the time and area of exposure. Erosion and sedimentation control plans
must incorporate mechanisms for minimizing adverse impacts to downstream areas by controlling
surface flows and sedimentation.
The Soil Erosion and �'edimentation Control Ordinance mandates buffer zonFl along
lakes and watercourses. : rown enforces the N.C. Environmental Managemr.—:�mmission's
26

more dwelling units per acre, but the overall project density must not exceed this limit. For
example, on a 20 acre tract, 10 units can be constructed on two acres, but the remaining 18
acres must be permanently dedicated as vegetated open space. The built -upon area (bua) of
any development, residential or non-residential, in the WS-II-CA watershed must not exceed six
percent of the total parcel area, and the remainder of the parcel must remain in its natural or
vegetated state. New development must preserve a minimum 50-foot vegetated buffer on all
sides of any perennial water as identified on the most recent version of the USGS 7.5 minute
topographic map.
The WS-III-CA overlay district allows single-family residential development at a density of
not more than one unit per acre of land, or a maximum of 12 percent bua for other residential and
non-residential development. The remainder of the parcel must remain in its natural or vegetated
state, and the stream buffer requirement is the same as in the WS-II-CA watershed.
The WS-III BW overlay district allows two dwellings per acre, or 24 percent bua. Non-
residential development must include sufficient parking for its intended uses, which is included in
the bua calculation. Section 2.116, paragraph C of the Zoning ordinance provides guidance for
calculating the minimum number of parking spaces that must be provided, depending on the
parcel's intended use. The remainder of the property must remain in its natural or undisturbed
state. New development must preserve a 30-foot wide vegetated buffer along any perennial
water indicated on the USGS topographic quadrangle. If built -upon area exceeds 24%, then a
100-foot undisturbed buffer along perennial streams must be maintained.
Non-residential buildings which will store, utilize, or generate toxic or hazardous
substances in any WS watershed must provide adequate spill containment structures.
The Zoning Ordinance supports the federal Clean Water Act by requiring that any person
applying for a Zoning Certificate that may affect wetlands must indicate on the submitted site plan
any wetlands on the property, and must obtain Section 404 authorization from the Army Corps of
Engineers before a Zoning Certificate will be issued. Section 404 permit applications (or pre -
construction notifications) are also reviewed by DWQ for Section 401 compliance. This local
regulation ensures that developers do not overlook the 404/401 requirements.
Under the Zoning Ordinance, the Board of Adjustment reserves the right to recommend
alternative development criteria, or impose development conditions or restrictions as it deems
necessary for the siting of cell towers. Decisions will be made on a case -by -case basis, and will
be governed by adjacent property compatibility or potential adverse impacts of proposed towers.
In the event of a federal nexus such as a Section 404 (wetlands) permit application, cell tower
siting may also be reviewed by the State Division of Archives and History, which may request a
viewscape (balloon) survey for proposed tall structures in the vicinity of properties listed on the
National Register of Historic Places.
6.2.2. Subdivision Ordinance.
The Highlands Subdivision Ordinance addresses subdivision development within the
Town and its ETJ. Preliminary plats must be approved by the Planning Board and
Commissioners before any street, utility, or public service shall be extended or connected to said
development. Preliminary plats must include property boundary lines, location of any significant
natural features, five-foot contour intervals, adjacent properties, proposed streets, utilities, and
stormwater layouts. Plans for propos*A streets outside the Town's planning area must be
accompanied by a letter of appro . _ :n the District Engineer of NCDOT. Sanitary sew:
25

i
Sedimentation Control Ordinance. The proposed treatment process upgrade has been designed to
provide a more advanced level of treatment than the speculative effluent limits require, including
biological nutrient removal and UV disinfection (section 5.8). Effluent quality will be better than that
from the existing WWTP, and several existing package WWTPs and hundreds of private septic
systems will ultimately be retired as a result of this project. Overall nutrient and chlorine loading to
the upper Cullasaja River basin will decrease. The potential direct environmental impacts of the
project are predominantly positive, and no further compensatory mitigation for direct impacts is likely
to be required as a condition of permit issuance or EA/FONSI approval.
6.2. Mitigation for Indirect and Cumulative Impacts.
The WWTP expansion is primarily intended to facilitate retirement of several package
WWTPs and numerous septic systems in the Lake Sequoyah watershed, but it will also
accommodate new development in the expanded wastewater service area. The wastewater flow
projections used for sizing the expansion are based on connecting the majority of existing
development within and outside town limits, plus infill of undeveloped platted lots in existing
residential subdivisions. The Town shall continue to enforce its policy of not providing water and
sewer service to an area unless that area is annexed into the Town. Once annexed, the area is
subject to all applicable Town ordinances and policies. New non-residential development is
expected to be minor, as nearly all undeveloped land in Highlands was down -zoned to low
density residential use a decade ago. Only a few small lots, all less than one acre, in the
downtown area with existing sewer service remain available for new commercial development.
The expansion does not include an allocation for new major development beyond existing
subdivisions.
A combination of federal, state, town, and county regulations and programs are
implemented in the proposed Highlands wastewater service area to mitigate the adverse effects
of urban growth. These include planning and zoning principles to control development density
and impervious surface area, encourage low -impact cluster development, and to preserve open
space and natural riparian vegetation. Town of Highlands ordinances and programs that protect
natural resource and reduce impacts of new development are summarized below.
6.2.1. Zoning and Watershed Ordinance.
The Highlands Zoning Ordinance regulates how and where specific types of development
may occur within the Town and its Extra -Territorial Jurisdiction (ETJ). The Zoning Ordinance
includes eight development categories (three residential, four business, and one
governmental/institutional) and three watershed overlay districts: 1) Big Creek Watershed Critical
Area (WS-II-CA), which comprises 132 acres (3 percent of service area) in northwestern
Highlands, 2) Lake Sequoyah/Mirror Lake Watershed Critical Area (WS-III-CA), which comprises
800 acres (16 percent of service area) in western Highlands, and 3) Lake Sequoyah/Mirror Lake
Balance of Watershed (WS-III-BW), which comprises most of the remaining service area (2,875
acres, or 56 percent). The ordinance defines specific guidelines and requirements for all
development activities proposed in each district of each category. Only 1,294 acres (25 percent)
of the proposed service area is outside of water supply watersheds, and designated Class B or
Class C (Figure 4).
Within the WS-II-CA overlay district, single-family residences may be constructed at a
density no greater than one :: lit per two acres. Cluster and multi -family developrne.1;3 allow
24

Two aquatic protected species (yellowfin shiner and turquoise darter) occur in the
Chattooga River and its tributaries downstream of the Highlands service area. Development in
the Chattooga (Savannah River) watershed, a minor portion of the Highlands service area, is
expected to be low density residential. Streams in this watershed will be protected in accordance
with their "trout waters" designation, and impacts to these two rare fish species should be minor.
Three terrestrial species (southern rock vole, green salamander, and Highlands moss)
have been reported within the proposed Highlands service area during recent years, and are
presumed extant. Many other species are not presently known within the service area, but might
occur there based on historic records, recent records nearby, or the presence of apparently
suitable habitat types (Table 3). Any of these species may be affected, directly or indirectly, by
future development supported by the WWTP expansion. Many of these species occur in
wetlands, humid gorges, waterfall spray zones, and steep rocky areas unlikely to be developed.
However, rare species populations in these sites may be adversely affected by development of
adjacent lands, due to habitat fragmentation, road mortality, stormwater impacts, invasive exotic
species, domestic animals, and micro -climatic changes, especially loss of shade and humidity.
Because the majority of new development is expected to occur as infill within existing
developments, the potential for impacts to these species is minor.
The Highlands Land Trust, a private non-profit organization (828-526-9938), is available to
assist the town and landowners in developing protection strategies for ecologically sensitive
lands, including rare species sites. In 1991-92 the Town contracted Dr. L.L. Gaddy to conduct a
natural areas inventory of the Highlands Plateau. Town planners use this document in planning
growth and reviewing development plans.
5.14. Introduction of Toxic Substances.
Potential sources of toxic substances during construction may include exhaust emissions,
oil, fuel, and other vehicle fluids. Escape of these substances will be minimized by proper vehicle
maintenance and collection and disposal of fluid containers. Contractors will be instructed to take
precautions to ensure that no uncured concrete is allowed to contact surface waters. Following
construction, the project is not expected to release hazardous or toxic quantities of substances.
The risk of toxic substance spills will be greatly reduced following the elimination of chlorine contact
disinfection.
Toxic substance loading to streams via stormwater runoff may increase as the service area
becomes more urbanized. Vehicle fluids, heavy metals, fertilizers, pesticides, detergents, paint,
solvents, pavement, and construction materials may contribute to stormwater toxicity. Strategies
that promote stormwater dispersal and soil infiltration rather than channeling it to streams will help
reduce stormwater pollution resulting from new development. These are discussed further in
section 6.2.
6.0. MITIGATIVE MEASURES
6.1. Mitigation for Direct Impacts.
Direct impacts of project construction and operation have been minimized through careful
project design. The expanded WWTP facilities will be built on previously cleared land containing no
woodland, wetlands, or streams, and ::r-»:-;truction will comply with Highlands' stringent Erosion a
23

s
5.12. Jurisdictional Wetland Impacts.
No ACOE jurisdictional are present on the WWTP site. Along sewerline construction
corridors, approximately 0.071 acre of wetlands will be impacted (Table 3). This small wetland
impact should be permitted under Nationwide Permit 12 (Utility Line Discharges) without
mitigation. As discussed in section 4.12, wetland impact was estimated based on preliminary
construction corridors, and a more precise impact determination will be calculated prior to
404/401 permitting.
Wetlands are most likely to occur in the service area on soils mapped as Toxaway (ToA),
Nikwasi (NkA), Sylva-Whiteside (SyA), or Rosman (RsA), which occur in generally narrow corridors
along streams (Thomas, 1996). Future development may cause minor loss and degradation of
wetlands in the service area. However, as the majority of new growth will be residential
development in existing subdivisions, and all subdivisions in the expanded service area must
comply with Highlands and/or Macon County water quality protection measures (section 6.2), the
potential for direct wetland impacts is small. Isolated wetlands not subject to ACOE protection will
be most vulnerable to degradation and Toss. Development of non -wetlands upslope may also
adversely affect adjacent wetlands. The majority of jurisdictional wetlands in the service area are in
floodplains unsuitable for buildings, although roads, golf courses, and other ground -level facilities
may be sited there with proper authorization. Future sewerlines needed to serve the expanded
area will be installed along roadsides wherever possible, minimizing stream and wetland impacts.
In September 2002 Highlands adopted a zoning amendment requiring that any person
applying for a Zoning Certificate that may affect wetlands must indicate on the submitted site plan
any wetlands on the property, and must obtain Section 404 authorization from the Army Corps of
Engineers before a Zoning Certificate will be issued. Section 404 permit applications (or pre -
construction notifications) are also reviewed by DWQ for Section 401 compliance. This local
regulation ensures that developers do not overlook federal Clean Water Act 404/401
requirements.
5.13. Protected Species Impacts.
No protected species is likely to occur in the proposed WWTP construction area, which is
previously cleared land, nor in the Cullasaja River Between Sequoyah Lake Dam (effluent
discharge) and Dry Falls. No direct impact to these species from WWTP construction is likely.
Habitats along the roadside sewerline construction corridors were assessed by RJG&A in
February 2003. Based on this survey, none of the listed species is likely to occur in these
corridors and no direct impact from construction is likely.
Four aquatic protected species (Little Tennessee rosyside dace, wounded darter, olive
darter, and hellbender) occur in the lower Cullasaja River between Cullasaja Gorge and the Town
of Franklin (Table 3, Appendix A). Several others apparently do not occur in the Cullasaja River
but may have occurred there historically, and might be re -introduced via translocation from extant
Little Tennessee River populations downstream of Lake Emory. The proposed wastewater
treatment improvements will yield a higher quality effluent that should benefit these species.
Conversely, future development in the service area may adversely affect downstream water
quality, but these impacts should be minimal due to the hydrologic effects of Lake Sequoyah and
Mirror Lake, combined with WS watershed protection rules and other measures (section 6.2).

5.9. Fish and Aquatic Habitat Impacts.
Impacts to fish and aquatic habitats include the water quality impacts discussed in section
5.8. No fish habitat occurs in the proposed WWTP construction area and no direct impacts of
construction are expected. New sewerlines crossing streams will be installed along roadsides,
which will minimize impacts to stream banks and riparian habitat. Aquatic habitat quality is
expected to improve downstream of the WWTP due to the proposed treatment process
improvements, which include nutrient removal and UV disinfection. Retirement of malfunctioning
septic systems and package WWTPs in the service area may improve water quality and fish
habitat in many of Highlands' small streams.
Indirect and cumulative impacts to fish habitat in the wastewater service area may result
future land clearing and development, as discussed in the preceding section. Future
development will be mostly residential and limited to platted lots in existing subdivisions, as
discussed in section 2.2 and the attached letter from Highlands Town Administrator Richard Betz
in Appendix E. Highlands has erosion control requirements more stringent than the state (section
6.2) and Lake Sequoyah will serve to trap the majority of sediment that escapes erosion control
measures. The lake will also help to mitigate peak storm flows and retain or assimilate urban
runoff pollutants. Therefore, future growth supported by this project is unlikely to affect aquatic
habitat in the Cullasaja River downstream of the lake.
Impacts of future development on aquatic habitat may also accrue in the Chatooga River
tributaries of southern and eastern Highlands, including several Tr and ORW streams. Although
these streams are not protected by the Water Supply Watershed Ordinance, the Town and
Macon County require natural vegetated buffers in accordance with these streams' Tr and ORW
designations. Because the expected development will be limited to residential construction in
existing platted subdivisions where the majority of roads are already in place, the potential for
adverse impacts is expected to be minor. Local programs and strategies to protect water quality
will also protect fish and aquatic habitat (section 6.2).
5.10. Wildlife and Terrestrial Habitat Impacts.
Because all project construction will take place within the existing WWTP fence on
previously disturbed and currently maintained land, no direct impacts to wildlife and terrestrial
habitats are anticipated. Indirect and cumulative impacts to wildlife and terrestrial habitats due to
urban growth in the expanded service area are likely. However, because the expected growth
will be predominantly residential construction in existing platted subdivisions, where few if any
new roads are needed, the potential for adverse impacts is expected to be minor. Many of the
water quality protection measures discussed in section 6.2 will also protect terrestrial habitats and
wildlife. Much of the land surrounding Highlands is National Forest and cannot be developed.
5.11. Forestry Resource Impacts.
Because all project construction will take place within the existing WWTP fence and along
existing roads on mostly disturbed and currently maintained land, direct impacts to forestry
resources will be negligible. Induced residential growth in the service area and annexation areas
may remove additional forest, but these impacts will be mostly confined to infill development of
vacant lots in existing subdivisions, as discussed in sections 5.2 and 5.10.
21

zoning decisions, preservation of forested buffers, and establishment of noise barriers for stationary
sources such as highways and major commercial areas will protect residential areas from excessive
noise.
5.8. Water Resources Impacts.
Direct water quality impacts during project construction will be negligible. No streams
occur in the proposed WWTP construction area, and no modification at the effluent discharge on
the Cullasaja River will be necessary. Soil erosion from the construction site will be minimized
following proper erosion and sedimentation control practices. New sewerlines crossing streams
along roadsides will be installed in accordance with ACOE and DWQ Nationwide Permit 12
conditions. The contractor will follow an approved Erosion and Sedimentation Control Plan
meeting all requirements of both DENR and the Town of Highlands ordinances, the latter of which
is more stringent than the state ordinance (section 6.2).
Expansion of the Highlands WWTP will triple the plant's permitted discharge capacity,
from 0.5 MGD to 1.5 MGD peak month average flow. Based on DWQ's estimated 7Q10 low flow
of 7.2 cfs, the instream waste concentration (IWC) will increase from a maximum of 9.7 percent at
0.5 MGD to 24.4 percent at 1.5 MGD. Speculative effluent limits for the expanded plant are
provided by DWQ, including ammonia-N and residual chlorine limits (Appendix D). The project as
currently proposed will also include biological nutrient removal and ultraviolet disinfection,
exceeding the treatment requirements needed to comply with the NPDES speculative limits.
Although effluent volume will increase, the concentrations of BOD, nitrogen, phosphorus, and
residual chlorine are expected to decrease. If total mass loadings of these pollutants decrease,
the net effect on downstream water quality is expected to be positive.
The WWTP improvements will allow future expansion of the Town's wastewater collection
system to unsewered areas, and subsequent retirement of older septic systems and package
WWTPs thatlack advanced treatment technology. Elimination of these facilities will reduce
potential sources of surface and groundwater contamination and eutrophication of Mirror Lake
and Lake Sequoyah.
This WWTP expansion project combined with future sewer extensions will accommodate
new development on undeveloped Tots within existing platted subdivisions. These subdivisions
have already received approval from either Highlands or Macon County, and would be developed
with on -site treatment systems if sewer is not provided. The flow projections used to size the
WWTP expansion (section 2.2) are based on build -out of existing playtted lots, and do not include
any allocation for new development outside of existing subdivisions. Increased impervious
surface from new development may reduce rainfall infiltration and cause higher peak stormflows
likely to destabilize stream channels and aggravate erosion, sedimentation, and pollution.
Reduced infiltration also reduces baseflow during dry weather and may cause small perennial
streams to become intermittent. However, the area of new impervious surface expected in the
Highlands area will be relatively small because the majority of roads in these subdivisions are
already built, leaving only the new houses and driveways as contributiors to new impervious area.
There is negligible land zoned for future commercial development in Highlands. Except for a few
small downtown parcels, nearly all undeveloped land in town was "downzoned" to residential
following Highland's 1989 Land Use Plan. Local programs and ordinances to manage
development and stormwater to minimize adverse water quality impacts of development are
discussed in section 6.2.
20

5.4. Public, Scenic, and Recreational Areas Impacts.
No public, scenic, or recreational areas occur in the WWTP construction area, and no
direct impacts will occur. The expanded WWTP will provide improved treatment and is unlikely to
adversely affect recreational use of the Cullasaja River.
Indirect impacts to public, scenic, or recreational areas resulting from residential or
commercial development in the service area may occur but will be minimized by the local
ordinances described in section 6.2.
5.5. Archaeological and Historic Resources Impacts.
Because SHPO responded with "no comment" during project scoping (Appendix B), no
cultural resources survey was conducted for this project and no direct impacts to archaeological
or historic resources are anticipated. The SHPO may comment further when the EA is circulated
for concurrence with a FONSI, should that be the conclusion of the lead agency. Indirect impacts
to cultural resources may accrue from future development in the expanded service area.
5.6. Air Quality Impacts.
An increase in airborne particulates from land disturbing activities and exhaust emissions
from construction vehicles will occur during construction, but public health impacts should be
negligible. Proper vehicle maintenance, frequent wetting of exposed soil, and prompt soil
stabilization will minimize impacts. Because no forest clearing is required for construction, there will
be no air quality impacts from burning woody debris.
The WWTP may emit odors produced by bacterial metabolism, but odor control mechanisms
will be incorporated into design and odors will be similar to those emitted by the existing facility.
Airborne particulates may temporarily increase near the WWTP when emergency generators are
used during power outages. These brief episodes will not significantly affect air quality.
Induced urban growth in the service area may cause an increase in air pollutant emissions
from vehicles and construction. Particulate matter interferes with human and animal respiration and
plant photosynthesis (N.C. Division of Air Quality, 2000). Carbon monoxide interferes with blood
oxygen uptake. Sulfur oxides and nitrogen oxides are corrosive, damage crops, forests, and
structural materials, and may aggravate respiratory and cardiovascular problems. Nitrogen oxides
exposed to sunlight also cause ground -level ozone formation. DAQ considers ozone the most
serious air pollutant in North Carolina, particularly during warm weather, with a wide range of
adverse impacts on human health, wildlife, crops, forests, and materials.
5.7. Noise Level Impacts.
Residents adjacent to the project area may experience nuisance noise levels during
construction, which will be limited to daylight hours. Operational noise of the facility will be negligible
and similar to current levels.
Urban growth in the service area induced by this project may create nuisance noise levels
due to traffic and construction in areas that are presently re►atively quiet. Careful plar and
19

will be restored. For the same reason, impacts to flood elevation will be negligible, except around
manholes where rims will be one foot above 100 year flood elevations.
Contractors are required to follow an approved Erosion and Sedimentation Control Plan to
minimize soil loss during construction. The plan will be submitted to the DENR Regional Office for
approval at least 30 days prior to construction, and the agency will be notified of the date that land -
disturbing activity will begin. Ground cover sufficient to restrain erosion will be in place within 15
working days or 90 calendar days (whichever is shorter) following completion of construction.
5.2. Land Use Impacts.
Because all proposed WWTP facilities will be constructed within the existing WWTP fence
line, no direct land use impacts will result in the project area. New sewerlines will be needed to
collect flows from the existing package WWTPs and septic systems that will be retired in the
expanded service area. These will be installed along developed roadsides where they will have
negligible land use impact.
Indirect and cumulative land use impacts may accrue as public sewer availability will facilitate
development on lots where on -site wastewater systems would be difficult and expensive. However,
overall development density is unlikely to be affected because the undeveloped lots to be served are
already platted, and cannot be further subdivided due to zoning. The expanded Highlands service
area (existing town limits plus five proposed annexation areas) contains 5,100 acres, or eight square
miles. The western portion (932 acres) including Lake Sequoyah, Big Creek, and the western half of
Mirror Lake is within WS-II and WS-III Critical Areas, where new development density is restricted to
6 percent and 12 percent impervious surface, respectively (Figure 4). The central 2,875 acres of the
Highlands service area is designated WS-III-BW (balance of watershed beyond the Critical Area),
which allows up to 24 percent impervious surface for new development. Vegetated buffers 50 feet
wide are required along perennial streams in WS critical areas, and 30 foot buffers are required in
WS-III-BW areas. Much of the downtown area, developed prior to the water supply watershed
protection rules, contains considerably higher development density and narrower stream buffers.
The southern and eastern portions of Highlands in the Chattooga River basin (1,219 acres) and a 75
acre area north of Lake Sequoyah that drains below the lake are not water supply watersheds and
do not have development density restrictions. However, these streams are designated trout waters,
which require a 25 foot vegetated buffer from new development. Zoning and development
regulations that mitigate impacts of new development are discussed further in section 6.2 and in
responses to DENR review comments in Appendix E.
5.3. Prime and Unique Farmlands Impacts.
Because no prime or unique farmland soils are found in the WWTP project area, there will
be no direct impacts to prime or unique farmlands.
Prime farmland soils exist in the service area and indirect impacts to prime farmlands
could result if development occurs in drainages or coves protected from flooding. The Town's
Sedimentation and Erosion Control Ordinance provides some protection from development in
such areas. The ordinance is discussed in section 6.2.2.
18

The Highlands area is geologically, topographically, and ecologically unique, even within the
context of the regionally unique southern Appalachian Mountains. Consequently, this area has an
unusually high concentration of rare species. The N.C. Natural Heritage Program (NHP) has
records of over 200 rare plants and animals known from Macon and Jackson counties, of which 71
are federally or state protected as endangered, threatened, or special concern. These protected
species are listed in Table 3 with their corresponding federal and state protection status and habitat
requirements. More detailed descriptions of each species, its habitat requirements, and likelihood
of occurrence in the Highlands service area are provided in Appendix A. This information was
compiled from Amoroso (1999), LeGrand and Hall (1999), Radford et al. (1968), Clark (1987),
Adams et al. (1990), Palmer and Braswell (1995), Menhinick and Braswell (1997), NHP and WRC
databases, and personal communication with agency biologists.
The proposed WWTP construction area was cleared and graded in 1994, and does not
provide suitable habitat for any of the protected species known to occur in Macon or Jackson
counties, based on a field survey by RJG&A biologists. None of these species is likely to occur on
the WWTP site, and no direct construction impact to protected species is likely. The proposed
sewerline extensions into existing subdivisions (currently using either septic systems or package
WWTPs) will be installed along roadsides in predominantly developed areas. These corridors
were surveyed for protected species habitats by RJG&A in February 2003. Although many rare
species would not have been detectable during this season, these corridors did not appear to
offer suitable habitat for any of the listed species, and the potential for adverse impacts to
protected species is unlikely.
The existing and future Highlands wastewater service area contains potentially suitable
habitat for many protected species, as documented in Appendix A and Table 3. Fifteen species
are unlikely to occur in either the service area or in the Cullasaja River or Chattooga River
tributaries downstream of Highlands, and will not be affected by this project; these are indicated
by the number "0" in the impacts column of Table 3. Six aquatic species do not occur in the
service area but are known from or expected to occur in the Cullasaja River or Chattooga River
tributaries downstream of Highlands, and may be affected by changes in the WWTP effluent or
stormwater impacts due to future development. These species are indicated by the number "1" in
the impacts column of Table 5. Forty-seven species are not presently known to occur in the
Highlands service area, but either occurred historically in the area or presently occur nearby.
These species may persist as unknown populations in the service area, or may be temporarily
extirpated but likely to recolonize suitable habitat in the service area, and are indicated by the
number "2" in the impacts column of Table 3. Finally, three species have recent NHP element
occurrence records within the service area, indicated by the number "3" in the impacts column of
Table 3, and could be subject to impacts of future development supported by the WWTP
expansion.
5.0. PREDICTED ENVIRONMENTAL IMPACTS.
5.1. Topography and Soil Impacts.
WWTP expansion will occur on approximately five acres entirely within the existing
WWTP fence line. Impacts to topography and soils in the WWTP area will be insignificant. The
ten foot wide sewerline corridors will occupy 15.3 acres of existing road rights of way. Impacts to
topography following sewerline construction will be negligible because original slope and contour
17

in section 4.10. Site indices for timber production on the major soil types in the Highlands area are
listed in Table 2.
4.12. Jurisdictional Wetlands and Waters.
RJG&A biologist Ward Marotti surveyed the WWTP construction site for jurisdictional
wetlands and waters on 30 January 2002 using the 1987 Army Corps of Engineers (ACOE)
Wetlands Delineation Manual (Environmental Laboratory, 1987), and supplementary technical
literature for hydrophytic vegetation, hydric soils, and wetland hydrology. No wetlands or streams
were found on the WWTP site. No new construction at the existing Cullasaja River effluent outfall
is proposed. Wetlands along the proposed sewer lines were surveyed during January 2003. The
approximate locations and acreages of impacts to jurisdictional wetlands and waters were
estimated based on the field reconnaissance and preliminary sewer alignments provided by the
engineers. More precise measurements of jurisdictional impacts will be determined in
conjunction with 404/401 permitting when final alignments are selected.
The proposed sewerline corridors needed to connect several existing neighborhoods to
the expanded WWTP will cross streams or wetlands at 34 sites, based on NRCS soil mapping
and field surveys by RJG&A biologists (Table 4). The largest proposed stream crossing is
number 29 at the Cullasaja River (Figure 5.1) which has 3.4 square miles of drainage basin area.
All other streams to be crossed have watersheds smaller than one square mile. Canada hemlock
dominates the forests along these streams, with rosebay, Ieucothoe, and mountain laurel
common as understory plants.
Seeps and small wetlands are common in the expanded service area. Proposed
sewerline corridors will cross jurisdictional wetlands at eight locations (Table 3, Figures 5.1
through 5.3). Hemlock forest dominates five of these and mowed vegetation dominates the
remaining three sites.
All proposed stream and wetland crossings are within existing road rights -of -way, and
most contain few riparian trees. Some of the stream and wetland impacts identified in Tables 3
and 4 and Figures 5.1 through 5.3 may be avoided if the sewerlines can be installed in the
existing road fill. Because final design has not been completed for the sewer lines, all potential
wetland and stream impacts within ten feet of existing roads are considered herein.
4.13. Protected Species.
Rare plant and animal species may be protected by the Federal Endangered Species Act,
administered by the U.S. Fish and Wildlife Service (FWS), and by two North Carolina laws: the
Plant Protection and Conservation Act, administered by the N.C. Department of Agriculture's Plant
Conservation Program (PCP), and the Endangered Wildlife Protection Act, administered by the
N.C. Wildlife Resources Commission (WRC). Protected species are those listed by FWS, WRC, or
PCP as endangered (E) or threatened (T), or listed by WRC or PCP as special concern (SC). Rare
species under consideration for future legal protection are designated as candidate (C), federal
species of concern (FSC), or significantly rare (SR) and are not legally protected. This document
addresses the potential for impacts on protected species only. Non -protected rare species were
excluded unless known to occur close to the project area.
16

Headwater tributaries in the Highlands area support few fish species, due to degradation
from urban impacts. The unimpacted segments support trout, dace, shiners, and sculpin. Several
Savannah River tributaries in southern and eastern Highlands are designated ORW, and most are
wild trout streams. Small headwater streams are also important to downstream aquatic
communities for their contribution to flow stabilization, thermal regulation, water quality protection,
nutrient processing, and benthic macroinvertebrate production.
Headwater stream segments too small, shallow, or steep for fishes provide habitat for semi -
aquatic invertebrates and salamanders that require streams or seeps with limited competition and
predation from fishes. Typical salamanders in seeps and headwater streams in the Highlands
vicinity include dusky salamanders (Desmognathus spp.), spring salamanders (Gyrinophilus spp.),
brook salamanders (Eurycea spp), and red salamanders (Pseodotriton spp.).
4.10. Wildlife and Terrestrial Habitats.
The proposed WWTP construction area is within the WWTP fence, and was cleared and
graded during construction of the original WWTP in 1994. It is urban land with negligible vegetation
or wildlife habitat value. Animals likely to occur on the WWTP property are limited to those that
tolerate urban and rural areas, including the five -lined skink (Eumeces fasciatus), Fowler's toad
(Bufo woodhousei), gray treefrog (Hyla chrysoscelis), house sparrow (Passer domesticus>, cardinal
(Cardinalls cardinalis), robin (Turdus migratorius), white -throated sparrow (Zonotrichia albicollis),
mockingbird (Mimus polyglottos), gray squirrel (Sciurus carolinensis), house mouse (Mus musculus),
raccoon (Procyon lotor), opossum (Didelphis virginiana), and big brown bat (Eptesicus fuscus).
Surrounding areas outside the WWTP fence and elsewhere in the Highlands wastewater
service area contain a variety of natural community types. These include high elevation red oak
forest, chestnut oak forest, rich cove forest, Canada hemlock forest, and montane alluvial forest,
following terminology of the N.C. Natural Heritage Program (NHP) community classification system
(Schafale and Weakley, 1990). Much of the service area is disturbed land (agricultural or
developed) that does not conform to the NHP classification.
Significant natural areas are designated by the N.C. Natural Heritage Program (NHP) if they
contain rare or protected species, high quality examples of relatively undisturbed natural
communities, or unusual geological features. They may be on public or private land, and their
designation as a natural area by NHP does not confer protection.
A natural areas inventory of the Highlands area was conducted in 1991-1992, with funding from
the Town. Six Registered Natural Heritage Areas occur within 1.5 miles of the Highlands WWTP
or service area: Cullasaja Gorge, Pinky Falls, Whiteside Mountain, Kelsey, Olive, and Satula
Mountain Summit (NHP archives, 10 January 2001). The Henry M. Wright Preserve is a
Dedicated Nature Preserve located within 1.5 miles of the service area. Table 4 lists these
natural areas, acreages, and ownership.
4.11. Forestry Resources.
No forests occur in the proposed WWTP construction area, which was cleared and graded in
1994. The proposed sewerlines will be installed within maintained road rights -of -way. Some of
these roadside corridors are predominantly mowed lawn and some contain trees, mainly hemlock
and oaks. Forest types beyond the WWTP fence and in the wastewater service area are described
15

ratings between benthos samples by DWQ and fish and mussel community samples by TVA and
others, this river segment is ecologically important. Maintaining high water quality in the Cullasaja
River helps maintain habitat integrity and protected species below Lake Emory.
4.8.4. Groundwater Resources.
Highlands is in the Blue Ridge Belt, in a region with mafic gneiss (GNM) and felsic gneiss
(GNF) the predominant hydrogeologic units. Average well yields in these formations are 20 gallons
per minute in the GNM unit and 17 gallons per minute in the GNF unit, standardized for a typical
154-foot deep, 6-inch diameter well (Daniel and Payne, 1990). Groundwater is generally of good
quality and adequate for low -density residential use. Rainfall in the Highlands area is the highest in
North Carolina, averaging 80 inches per year, providing ample groundwater recharge.
4.9. Fish and Aquatic Habitats.
The Cullasaja River below Lake Sequoyah is approximately 40 feet wide with a substratum
of predominantly cobbles and bedrock. In the immediate vicinity of the outfall, boulders and
bedrock are present, but not riverweed (Podostemum ceratophyllum). The riverbanks and narrow
flood plains are forested, except where US Highway 64 parallels the north bank. The river gradient
is steep, dropping 350 feet over rapids and falls from Lake Sequoyah Dam to the base of Dry Falls
1.5 miles downstream. For several decades prior to 1967, aquatic habitat below Lake Sequoyah
was stressed by dam retention for hydroelectric power generation that reduced flows. No minimum
instream flow release was required then, and nearly all the river's flow was detained in Lake
Sequoyah during low flow conditions. Consequently, few fish species remain between Lake
Sequoyah Dam and Dry Falls (William McLarney, personal communication).
Typical fishes in the Cullasaja River and tributaries between Dry Falls and Franklin include
the mountain brook lamprey (lchthyomyzon greeleyi), native brook trout (Salvelinus fontinalis),
western rainbow trout (Oncorhynchus mykiss), exotic brown trout (Saimo trutta), stoneroller
(Campostoma anomalum), river chub (Nocomis micropogon), whitetail shiner (Cyprinella
galacturus), Tennessee shiner (Notropis leuciodus), mirror shiner (Notropis spectrunculus),
warpaint shiner (Luxilus coccogenis), fatlips minnow (Phenacobius crassilabrum), blacknose dace
(Rhinichthys atratulus), longnose dace (Rhinichthys cataractae), creek chub (Semotilus
atromaculatus), northern hog sucker (Hypentellum nigricans), rock bass (Ambloplites rupestris),
redbreast sunfish (Lepomis auritus), bluegill (Lepomis macrochirus), smallmouth bass (Micropterus
dolomieu), greenside darter (Etheostoma blennioides), greenfin darter (Etheostoma
chlorobranchium), gilt darter (Percina evides), and mottled sculpin (Cottus bairdi), based on
Menhinick (1991) and field observations.
Rare and protected fish species known from the Cullasaja River include the Tennessee
River subspecies of the rosyside dace (Cllnostomus funduloides.), wounded darter (Etheostoma
vulneratum), and olive darter (Percina squamata), based on Menhinick and Braswell (1997). The
hellbender (Cryptobranchus alleganiensis), North America's largest salamander, may also occur in
the lower Cullasaja River. These protected species are discussed further in section 4.13.
Impoundments in the Highlands area, including Mirror Lake and Lake Sequoyah, support
primarily stocked trout, smallmouth bass, largemouth bass (Micropterus salmoides), rock bass,
and sunfishes (Fish, 1969).
14

data (Mark McIntyre, DWQ, personal communication). Average flow at the new gage during the
lowest 7-day period to date was 8.0 cfs (August 9 to 15, 2002), and the lowest instantaneous flow
recorded was 6.8 cfs, during an exceptional drought. These flows include the wastewater effluent
(0.3 to 0.5 cfs) plus runoff from 4.3 square miles of additional drainage area below the discharge.
Adjusting for drainage basin area and subtracting the WWTP flow, the estimated 7-day average
flow immediately above the effluent discharge during that week was 5.6 cfs.
From the Highlands WWTP below Lake Sequoyah to Cullasaja Gorge, the Cullasaja River
flows six miles through Nantahala National Forest. Water quality improves progressively
downstream through this segment as a result of turbulent aeration and inflow of high quality
tributaries draining undeveloped land. The uppermost DWQ benthos site B-13, 0.7 mile below
Lake Sequoyah, was rated good -fair in 1990, 1991, 1994, and 1996. Species richness declined
slightly from 27 EPT taxa (aquatic insects used as indicators of good water quality) in 1994 to 20
EPT taxa in 1996 samples, after the new WWTP began operation, but not enough to lower the
water quality rating. Site B-14 at Jackson Hole is five miles downstream, above the mouth of Brush
Creek, and rated excellent (49 EPT taxa) in 1999.
Below Cullasaja Gorge the river leaves U.S. Forest Service land and the surrounding land
becomes rural residential, agricultural, and forestry. Despite human impacts, the biological
condition of the Cullasaja River remains good to excellent for several more miles. Four benthos
samples between 1991 and 1999 at Site B-15 (SR 1678) near Peeks Creek were rated excellent
(42 to 50 EPT taxa), and fish community samples by Dr. McLarney near Peaceful Cove (below
Walnut Creek) during the past decade were rated good. Continuing downstream, DWQ Site B-16
(SR 1524) rated good in 1991 and 1996 (35 and 37 EPT taxa), and Site B-17 (SR 1668) three miles
upstream of Franklin rated excellent in 1999 (51 EPT taxa). Five tributaries along this river
segment were sampled in 1999; four were rated excellent (Turtle Pond Creek, Brush Creek, Buck
Creek, and Ellijay Creek) and one was rated good (Walnut Creek). Overall water quality in the
middle section of the Cullasaja River (Sites B-14 to B-17) has remained high throughout the past
decade of biological sampling. No data earlier than 1990 were reported.
The Cullasaja River's drainage basin area increases to 92 square miles before joining the
Little Tennessee River at Franklin, 16 river miles downstream of Lake Sequoyah. The lowermost
two-mile segment is adversely affected by agriculture and development east of Franklin, and habitat
quality in this segment is poor (Dr. William McLarney, personal communication). No DWQ data
were reported for this segment.
Lake Emory, just below the confluence of Cullasaja River and Little Tennessee River in
Franklin, was eutrophic in 1988 with high suspended solids, chlorophyll -a, and nutrient
concentrations. By 1994 chlorophyll -a and nutrient concentrations had decreased substantially and
the lake's trophic status was oligotrophic. The phosphate detergent ban, improvements at Franklin's
WWTP, uptake of nutrients by wetlands at the head of the lake, and the closing of a large farm
along the Little Tennessee River upstream of Franklin may have contributed to the observed water
quality improvements. No subsequent data for Lake Emory were reported (NC Division of Water
Quality, 1997, 2000).
The Little Tennessee River at NC-28 near lotla downstream of Franklin was rated good -fair
to good based on benthos and ambient chemical sampling by DWQ from 1983 to 1999 (NC
Division of Water Quality, 1997, 2000). However, fish community sampling by TVA yielded good to
excellent ratings in the Little Tennessee River at several sites between Lake Emory dam and
southern Swain County (Dr. William McLarney, personal communication). Apparently healthy
populations of several federal and state protected fishes and mussels occur in this river segment,
species extirpated from rr,- ==+ .--her streams in their historic range. Despite the disc r, r - ;cy in
13

minimize erosion. Highlands has made significant progress on some of these recommendations,
as discussed in the mitigation section of this EA and Appendix E.
4.8.3.2. Lake Sequoyah.
DWQ evaluated the trophic status of Lake Sequoyah in 1988 (prior to the NC phosphate
detergent ban) and found eutrophic conditions. The lake's use support status was listed as
"support threatened" based on that study. Six years later Lake Sequoyah was classified as
mesotrophic, with elevated chlorophyll -a and nutrient concentrations and anoxic hypolimnetic
waters. (However, the predominant algae collected in 1994 were not species typically associated
with nuisance blooms or taste and odor problems.) Based on these data, the lake was once again
rated "support threatened" in the Basinwide Management Plan (NC Division of Water Quality,
1997). Concern over further water quality degradation in the lakes and need for additional
wastewater treatment capacity prompted the Town to retire the 0.25 MGD WWTP on Mill Creek
upstream of Mirror Lake, and replace it in 1994 with the current 0.50 MGD WWTP below Lake
Sequoyah. This action eliminated a significant source of BOD and nutrient loading to the two lakes.
A Iimnological study of Lake Sequoyah was commissioned by Highlands from May through
October 1997, when water demand began to exceed the safe yield that Big Creek alone could
provide. No nuisance algal bloom occurred during that study. The predominant algal species were
not known to cause taste and odor problems. No water quality problem was apparent in 1997 that
would impair the lake's use as a public raw water supply, despite extensive development close to
the lake. A 1999 study of Lake Sequoyah revealed mesotrophic to moderately eutrophic
conditions, with chlorophyll -a concentrations consistently above DWQ's 15pg/I standard for trout
waters. Seven species of odor -causing algae were detected, but the Town's WTP superintendent
reported no taste or odor complaints about the treated water.
Lake Sequoyah is now rated "supporting" in the latest Basinwide Assessment Report and
Draft Basinwide Management Plan (NC Division of Water Quality, 2000, 2001). The Draft
Basinwide Management Plan commends Highlands for its adoption of an Erosion Control
Ordinance and Subdivision Regulations in 1995. The Plan encourages the Town to fully
implement and enforce these rules and its 1993 Watershed Protection Ordinance, and to develop
better stormwater management plans. Stream and riparian restoration are also recommended in
the Highlands area.
4.8.3.3. Cullasaja River Below Lake Sequoyah.
The Cullasaja River near the Highlands WWTP has a drainage basin area (dba) of 14.5
square miles. Mean annual flow typically ranges between 50 and 70 cfs, or 3.3 to 4.6 cfs per
square mile, based on a USGS gage that operated 0.6 mile downstream of Lake Sequoyah Dam
from 1931 to 1971 (Giese and Mason, 1991; USGS website). During most of this period the river
was used for hydroelectric power generation with no minimum release flow requirement, and the
7Q10 low flow for this period is 2.4 cfs (Upper Cullasaja Watershed Association, 2001 Year -End
Report). The hydroelectric plant was abandoned in 1967, and the USGS gage below Lake
Sequoyah Dam was discontinued in 1971.
In July 2001, USGS installed a new streamflow gage on the Cullasaja River at SR 1620,
two miles downstream of Lake Sequoyah dam (dba = 18.8 square miles). The present 7Q10 low
flow above the V' `.NTP discharge is estimated at 7.2 cfs, based on the ne',. gage and historic flow
12

4.8.3. Existing Surface Water Quality.
4.8.3.1. Cullasaja River Above Lake Sequoyah.
From its headwaters on a golf course four miles northeast of Highlands to Lake Sequoyah
dam, the Cullasaja River flows through residential, commercial, and forested land. Much of this
area was in agricultural or commercial forestry prior to residential development, and the river is
affected by erosion, sedimentation, and impoundment from past and current land uses. Roads and
development encroach close to the river, with little or no riparian buffer along many segments.
However, some northern Cullasaja River tributaries that originate and remain in predominantly
forested watersheds such as Big Creek support wild trout populations.
Water quality ratings in streams based on benthic macroinvertebrate (benthos) and fish
sampling indicate fair to poor conditions in the Cullasaja River upstream of Mirror Lake, based on
four benthos samples by DWQ between 199G and 1999 (NC Division of Water Quality, 2000) and
fish community sampling by Dr. William McLarney. Mill Creek, which flows through downtown
Highlands, was rated fair both above and below the old WWTP in 1990 and 1991. A 1999 benthos
sample below the old WWTP (five years after WWTP retirement) was also rated fair. Urban and
golf course development in the Mill Creek watershed limit this stream's potential for biological
recovery. Big Creek upstream of the Highlands raw water intake was rated excellent based on a
first-time benthos sample in 1999.
The 1997 use support ratings for these streams are as follows: Cullasaja River and Mirror
Lake upstream of SR 1545, not supporting; Cullasaja River and Mirror Lake downstream of SR
1545, supporting; Mill Creek, partially supporting; Big Creek and Monger Creek, supporting (NC
Division of Water Quality, 1997, 2000). The Draft 2002 Basinwide Plan (December 2001) use •
support ratings for these streams are unchanged from the 1997 ratings. Cullasaja River and Mill
Creek are listed as high priority streams for recovery efforts based on lowering the total maximum
daily loads (TMDLs) of pollutants under the Clean Water Act section 303(d) list of impaired waters.
DWQ recently conducted a special biological monitoring study of the Cullasaja River and
Mill Creek upstream of Mirror Lake, with funding from the N.C. Clean Water Management Trust
Fund. The study evaluated benthos communities, channel morphology, riparian and instream
habitat condition, water and sediment chemistry, land use, and pollutant sources in the watershed.
The Draft Report (April 2002) identifies several problems that contribute to biological impairment in
these streams, including: 1) insufficient large woody debris and other instream habitat structure; 2)
inadequate forested riparian buffers; 3) channel erosion from urban stormwater runoff; 4) toxic
pollutants in runoff from urban areas and golf courses; 5) impaired dispersal and recolonization of
aquatic animals due to dams; 6) water quality effects of dams on stream temperature, dissolved
oxygen, and nutrient cycling; 7) impaired sediment transport due to dams; 8) reduced stream flow in
dry weather due to irrigation withdrawals and evaporation from lakes; and 9) lack of healthy stream
refugia from which recolonization may occur.
The report recommends several general strategies to mitigate these problems, including 1)
develop a strategy to reduceimpacts of dams and promote recolonization of aquatic life from
healthy streams; 2) restore forested riparian buffers where practicable; 3) enhance instream habitat
by adding boulder clusters and logs where appropriate; 4) review nutrient and pesticide
management plans of local golf courses, and revise plans or operating procedures if necessary; 5)
educate homeowners and landscape contractors regarding fertilizer, seeding, and pesticide use; 6)
educate homeowners and builders regarding importance of forested riparian buffers and on -site
infiltration of stormwater; 7) detPr.lop local regulations to control development on steer s;.. 2es and
11

(Thomas, 1996) shows all of the streams indicated by USGS plus many additional tributaries
throughout the Highlands service area, both perennial and intermittent.
4.8.2. Surface Water Usage Classifications.
The N.C. Division of Water Quality (DWQ) classifies surface waters based on their "existing
or contemplated best usage." The primary classification system distinguishes three basic usage
categories: waters used for municipal water supply (Classes WS-I through WS-V), waters used for
frequent body contact (Class B), and waters used for neither of these purposes (Class C). Class C
uses include maintenance of aquatic life, fishing, wildlife habitat, secondary recreation (limited body
contact), wastewater assimilation, and agriculture. Water Supply Critical Areas (WS-II-CA through
WS-IV-CA) assigned by DWQ extend 0.5 mile upstream of run -of -river water intakes or 0.5 mile
upstream of the normal pool elevation for reservoir intakes.
Supplemental DWQ classifications include NSW for nutrient -sensitive waters where
nuisance algal blooms are likely, Tr for trout waters that require low temperatures and high
dissolved oxygen, Sw for swamp waters that have naturally low pH and low dissolved oxygen,
ORW for outstanding resource waters with special recreational or ecological significance, and HQW
for high quality waters that have excellent water quality based on physical, chemical, and biological
measurements. One or more supplemental classifications may apply to waters of any primary
classification. Waters identified by the N.C. Wildlife Resources Commission (WRC) as critical
habitat for protected species may be designated HQW.
The Cullasaja River headwaters upstream of SR 1545 in Highlands, including Ravenel Lake
and the upper half of Mirror Lake, is classified WS-III-Tr. From SR 1545 (crossing Mirror Lake)
downstream to Lake Sequoyah Dam the river is classified WS-III-CA-Tr, to protect Lake Sequoyah
for water supply use. The remainder of the Cullasaja River from Lake Sequoyah Dam downstream
to its confluence with the Little Tennessee River near Franklin is classified B-Tr. The B
classification is assigned to protect the river's recreational and baptism uses. The Highlands
WWTP discharges to the Cullasaja River just below Lake Sequoyah dam. Stream classifications
and protected watersheds in the Highlands service area are mapped in Figure 3.
Cullasaja River tributaries and their lakes upstream of Lake Sequoyah, other than Big
Creek, are classified WS-III or WS-III-Tr, and their lower reaches within 0.5 mile of Lake Sequoyah
are WS-III-CA. Big Creek (including Randall Lake) is classified WS-II-Tr, with a 0.7 mile CA above
Lake Sequoyah. Houston Branch, a northern tributary of Big Creek, is classified WS-I upstream of
Highlands Reservoir (beyond the proposed wastewater service area). Class WS-I watersheds are
in undeveloped land, and are not assigned a critical area.
In the Savannah River basin, East Fork Overflow Creek, Little Creek, Edwards Creek, and
Big Creek are classified C-Tr-ORW. Brooks Creek and Clear Creek are classified B-Tr. Norton Mill
Creek and Cane Creek are classified C-Tr. There is no designated water supply watershed in the
Savannah River portion of the Highlands service area.
Protected water supply watersheds comprise 75 percent of the 5,100 acre expanded
wastewater service area (Figure 4). This includes 132 acres of WS-2-CA watershed and 800 acres
of WS-3-CA watershed surrounding Lake Sequoyah and the western half of Mirror Lake, and 2,875
acres of WS-3 watershed (balance of Lake Sequoyah watershed). Non -water supply watersheds
comprise 25 percent of the future service area, including 872 acres of Class C watershed and 422
acres of Class P watershed, mostly in the Chattooga River basin.
10

r,
2001). Air quality standards are based on hourly, daily, quarterly, or annual averages, depending
on each pollutant's physical properties, chemical dynamics, human physiological responses, and
monitoring technology (N.C. Division of Air Quality, 1998). Primary air quality standards are those
established for protection of public health. For some pollutants secondary standards are
established to protect against adverse effects on soil, water, crops, vegetation, animals, materials,
climate, visibility, and personal comfort.
Ambient air quality data from two DAQ monitoring stations in Haywood and Swain counties
during 1998 and 1999 are presented in Table 1 (N.C. Division of Air Quality, 2001). Macon County
has no DAQ monitoring stations. Neither Macon nor adjacent counties have been designated EPA
non -attainment areas, and automobile emission testing is not required in these counties. Haywood
County, Tying northeast of Macon County, will require emission testing by July 01, 2005. Macon
County is not scheduled to require automobile emissions testing in the near future.
4.7. Noise Levels.
Noise is subject to the federal Noise Control Act of 1972 (PL-92-574). and Quiet Communities
Act of 1978 (PL-95-6009), which require standards of compliance and recommend approaches to
abatement for stationary noise sources such as airports, highways, and industrial facilities. No
facilities subject to federal noise regulation are located in the Highlands service area.
4.8. Water Resources.
4.8.1. Surface Water Hydrology.
The majority of the Highlands wastewater service area is drained by the Cullasaja River and
its headwater tributaries in DWQ sub -basin 04-04-01 of the Little Tennessee River basin. Major
tributaries of the Cullasaja River in the Highlands area include Saltrock Branch, Ammons Branch,
Mill Creek, Monger Creek, and Big Creek. Lake Sequoyah and Mirror Lake are large
impoundments on the main stem of the Cullasaja River. Smaller impoundments on tributaries
include Ravenel Lake, Harris Lake, Club Lake, Randall Lake, and even smaller ponds and lakes
built for resort development.
Highlands' raw water intake is located on Big Creek near the point where it widens into Lake
Sequoyah. The drainage basin area of Big Creek at the intake is 5.3 square miles, mean annual
flow is approximately 20 cfs, and the 7-day duration 10-year frequency (7Q10) low flow is
approximately 2.0 cfs (Giese and Mason, 1991). During low flow conditions the intake may reverse
the direction of flow in the Big Creek arm of the lake, drawing water from the main channel of Lake
Sequoyah.
The southernmost and easternmost portions of the Highlands service area are drained by
headwater tributaries of the Chattooga River in DWQ sub -basin 03-13-01 of the Savannah River
basin. Streams in these areas include East Fork Overflow Creek, Brooks Creek, Clear Creek,
Edwards Creek, Little Creek, Big Creek, Cane Creek, and Norton Mill Creek. None of these
streams is used for public water supply.
All streams in the proposed Highlands service area that are mapped on the USGS 7.5
minute topographic quadrangle of Highlands are indicated as solid lines (perennial). No intermittent
streams are mapper i USGS in the project service area. The Soil Survey 4 !..flacon County
9

industry. Another 1,100 acres containing resorts and residential development north and west of the
Town limits are under study for annexation. In the annexation areas, hemlock forest dominates
low-lying areas with mixed oak forest on well drained hillsides and ridges. The Cullasaja Club at
the head of the Cullasaja River four miles northeast of Highlands is beyond the proposed service
area. Much of the surrounding land is in the Nantahala National Forest and Nantahala Game
Lands.
4.3. Prime and Unique Farmlands.
Twelve prime farmland soils occur in Macon County, and three occur in the service area.
Toxaway loam (ToA), Rosman fine sandy loam (RsA), and Tuckaseigee-Whiteside complex
(TwB) are prime farmland soils when drained, protected from flooding, or not frequently flooded
(Thomas, 1996). They occur in the service area along streams and in coves. No prime farmland
soils occur on the WWTP site.
Leon, Lynn Haven, and Murville soil series are designated unique farmland soils in North
Carolina, but none occurs in Macon County. Developed land no longer qualifies as prime or unique
farmland, regardless of soil type.
4.4. Public, Scenic, and Recreational Areas.
Nantahala National Forest bounds Highlands to the west, north, and east and the
Nantahala Game Land marks Highland's southern boundary. These public lands offer
recreational opportunities that include hiking, rafting, scenic waterfalls, overlooks, hunting, and
world -class trout fishing. The area features several private and one public golf course. Highlands
Recreation Park provides swimming, tennis, exercise equipment, and summer programs for
children. The Natural Heritage Program (NHP) lists Registered Heritage Areas and Dedicated
Nature Preserves in Macon County. Those within 1.5 miles of the project and service areas are
discussed in section 4.10.7.
4.5. Archaeological and Historic Resources.
The State Historic Preservation Office (SHPO) indicated "no comment" in its 4 February
2002 response to the project scoping letter (Appendix B). SHPO offers this response for projects
they believe are unlikely to affect significant archaeological or historical resources, either because
the area has already been adequately surveyed, or because the setting and land use have low
probability for yielding artifacts.
4.6. Air Quality.
The N.C. Division of Air Quality (DAQ) and U.S. Environmental Protection Agency (EPA)
have established ambient air quality standards for major air quality pollutants including particulates
(TSP and PM-10), sulfur oxides (SOX), nitrogen oxides (NO.), volatile organic compounds (VOCs),
carbon monoxide (CO), and ground -level ozone (03). North Carolina has not routinely monitored
for ambient lead (Pb) since 1982 because of already low Pb levels and a decrease since the
elimination of leaded gasoline. A 1999 arsenic study that included Pb sampling confirmed that the
decrease ha-. .Inued, with only 39 of 526 samples above minimum ction levels (DAQ,
8

The release of significant toxic pollutants and excess nutrients affects a broad array of sensitive
fishes (such as some darters) and macroinvetebrates (including the EPT groups typically used as
indicators of good water quality). These infrequent, chronic, or excessive adverse events are
detected by the disappearance or decline in numbers of sensitive species, frequently with an
increase in the array of pollution tolerant species (such as certain chironomid insects known as
midges and of certain tubificid oligochaete worms). It is for these reasons that regulatory
agencies require and conduct biological monitoring in addition to chemistry analyses.
Wild and Scenic River designation confers protections that include limits on new NPDES
permits, and limits on riparian and instream uses. Consideration by the Town is recommended.
However, designation is not related to the review process for approval of a wastewater treatment
plant expansion. Collection and disposal of public sewerage is a public health issue. Regulatory
agencies are concerned with efficiency, costs, benefits, and mitigation of unavoidable adverse
impacts of this project on its own merits.
4.0. EXISTING ENVIRONMENT.
4.1. Topography and Soils.
Topography in the Highlands service area is primarily steep -sloped mountains and broad
valleys. Elevations range from 3,600 feet at Lake Sequoyah Dam to 4,300 feet in ridge top
developments (USGS topographic quadrangle of Highlands N.C.). The downtown area is at 3,800
feet, and the WWTP site is at 3650 feet elevation. Conspicuous landforms in the service area
include Bearpen Mountain, Little Bearpen Mountain, Little Yellow Mountain, Holt Knob, Wildcat
Gap, Dog Mountain, and Satulah Mountain.
Highlands is in the Blue Ridge Belt geologic formation, comprised of biotite gneiss, schist,
amphibolite, and intrusive quartz diorite/granodiorite (N.C. Division of Land Resources, 1985). The
predominant upland soils in the Highlands area are Edneyville-Chestnut complex (Ed and Ee),
Chandler gravelly fine sandy loam (Cd), Cleveland -Chestnut -Rock ouctrop complex (Cp), and Plott
fine sandy loam (Pw), which occur on ridges and slopes of eight to 95 percent (Thomas, 1996).
The majority of developed land is on slopes less than 30 percent, and the steeper areas are mostly
forested. Predominant soils along stream corridors are Tuckaseigee-Whiteside complex (TwC) on
riparian slopes, and Sylva-Whiteside complex (SyA), Nikwasi loam (NkA), Rosman fine sandy loam
(RsA), and Toxaway loam (ToA) on floodplains. Many floodplain areas are in agriculture or golf
course use. There are currently no FEMA-designated floodplains in Highlands.
4.2. Land Use.
The area proposed for WWTP expansion is within the existing fence, and was cleared and
graded when the original WWTP was built in 1994. Soils on the site are mapped as Plott fine
sandy loam and Edneyville-Chestnut complex (Thomas, 1996). The surrounding land outside the
fence is mostly forested with hemlock and hardwoods.
The Town of Highlands encompasses 3,600 acres in southeastern Macon County and 400
acres in southwestern Jackson County. Highlands straddles the watershed divide between the
Cullasaja River (Little Tennessee River basin) to the north and west, and the Chattooga River
(Savannah River basin) to the south and east. The predominant land uses are residential and
resort development, with `r: + ! +=.m as the principal commercial development. There r: heavy

The layout for the expanded treatment facility includes dual train (parallel path) for the
major treatment units and the following future components:
• 0.25 MGD Sequencing Batch Reactor
• 0.75 MGD Sequencing Batch Reactor
• Two 78,000 GPD Aerobic Digesters
• One 162,000 GPD Post Equalization Tank
• Ultraviolet Disinfection
• Aerated Digester
• Building for Sludge Conditioning and Maintenance
• Sludge Belt Press
• Stand-by Generator
The total estimated capital costs for WWTP expansion with 100 percent surface water
discharge is $3,002,470. This is the preferred alternative.
3.7. Additional Considerations.
During the public informational meeting and in public comments received thereafter,
several non -governmental stakeholders requested consideration of moving the discharge to the
head of Lake Sequoyah, to providing chemistry data in addition to biological data, and to
endorsing a proposal to request Wild and Scenic River designation for the Cullasaja River
(Appendix C).
Comments from state regulators endorsed the proposed discharge location downstream
of the lakes into the Cullasaja River. The environmental consultants concur and offer the view
that this high gradient river provides more efficient mixing and assimilation of wastewater than a
lake. Additionally, the lake has experienced anoxic conditions at the bottom in the past, and it is
more vulnerable to the adverse effects of waste loading than the river. The benefits of lake
discharge, according to stakeholders, include river protection and a public display of confidence
in the treatment process. Public displays of confidence are not suitable considerations in the
preparation of an environmental document that compares the costs and benefits of alternatives.
Protection of the river has been addressed in the treatment process and will be required by state
regulatory agencies through specific actions that will be a condition of approval of this EA.
Providing chemistry data in addition to biological data would indeed offer more
information, but the quality of the information would depend on the location, frequency, and
selection of suitable monitoring parameters. North Carolina and other states require limited
sampling for water chemistry at the intake and at the discharge for all NPDES holders. Expanding
the sampling and analysis program would increase costs that would not be reimbursed because
they would not be mandated conditions of the permit or of operation.
An explanation of biological monitoring may help stakeholders understand why the state
emphasizes, as do other states, biological monitoring. Chemical monitoring detects instantaneous
conditions. If the water sample is taken before or after an adverse event, the event remains
undetected.
Biological monitoring, on the other hand, does not measure instantaneous conditions, but
the resulting conditions following days, months, or even years of exposure to infrequent, short
term, or chror.:,_ =..-Verse events such as the release of toxic substance ; .-)r excessive nutrients.
6

The Franklin WWTP has a capacity of 1.65 MGD and adequate treatment capacity to accept
all of Highlands' present wastewater flow. However, Franklin has not shown interest in the
regionalization of sewer facilities. Their current WWTP may also need expansion in the near future.
The North Carolina Department of Transportation (NCDOT) would require encroachment
agreements for force main installation along NCDOT rights -of -way. This option assumes that force
main encroachments could be obtained along NCDOT roads. This option is not practical because of
the 14 to 19 mile distance required to connect the systems. The Franklin WWTP would require
additional capacity to handle Highlands' flow in addition to Franklin's long term projected flow.
Therefore, this option was not considered further and a detailed cost analysis is was not prepared.
3.5. On -Site Wastewater System for Treatment Plant Effluent.
Similar to the Spray Irrigation option (3.2), this on -site system would discharge one third of
the projected 1.5 MGD design capacity, requiring 208,333 linear feet of a chamber infiltrator. This
would require a minimum of 67 acres for septic fields and an additional 67 acres for the repair area,
assuming a site with uniform slopes could be found. Discharge of 100 percent of the plant effluent
into this system would require at least 400 acres.
This system is more expensive and requires more area than a spray irrigation system of
equal capacity. Land costs in the Highlands area would be the greatest expense. Because a spray
irrigation system would require less area, the on -site option was not considered further and a
detailed cost analysis was no prepared.
3.6. Expand Highlands WWTP and Stream Discharge (Preferred Alt).
The Town's WWTP was designed and constructed for a future expansion to 1.5 MGD and
would accommodate the 20-year future average daily flow described in section 2.2.
The current NPDES permit (NC0021407) stipulates typical secondary effluent limitations.
It is assumed that effluent limitations for the expanded plant will require tertiary treatment which
will provide a higher quality effluent and better protect the Cullasaja River. Tertiary filters and
ultraviolet disinfection are included in the plan for the proposed WWTP.
The existing facilities consist of two 0.25 MGD sequencing batch reactors (SBRs) with
room to increase capacity to 1.5 MGD with the addition of another two SBRs of 0.25 and 0.75
MGD. The capacity of the post equalization tank will be tripled from 0.081 MGD to 0.243 MGD
with the addition of a 0.162 MGD tank. Additionally, two 0.078 MGD aerobic digesters will triple
the capacity of the existing digester.
Sludge is currently disposed of at the Macon County Landfill. This practice would
continue following expansion. New sludge dewatering facilities will be added and a sludge belt
press constructed. These facilities are reliable, cost effective and easy to operate.
The new facility will be protected to at least one foot above the 100-year flood level by
extending tanks and related equipment above grade and by filling in the vicinity of the treatment
plant. The buildings and the sludge belt press need to be accessible at grade and fill would be
required in these areas.
5

spray irrigation system consists of the treatment plant, irrigation pump station and distribution
piping and spray nozzles.
Spray irrigation systems require a large area for the distribution of effluent. Based on the
assumptions above, an area of approximately 110 acres would be required, including 100-foot
buffers, to discharge 0.5 MGD through spray irrigation.
Land acquisition would be the major cost. Because of the mountainous terrain, finding a
suitable site this large would be difficult. A high percentage of soils in the area are of the
Edneyville, Plott and Cullasaja series, and are not suitable for absorption fields. Spray irrigation
onto golf courses has been successful elsewhere.
The capital cost of developing a 0.5 MGD spray irrigation system is $2,992,300 in addition
to the estimated $3,000,000 WWTP expansion costs. Because this option doubles capital
expenditure compared with the 100 percent surface water discharge, it was not considered
further.
3.3. Connect to Cashiers System.
The Township of Cashiers is located 12.7 miles northeast of Highlands. Under this option,
the Highlands WWTP would be abandoned and the Highlands collection system would be
connected to the Cashiers collection system. The Cashiers WWTP and collection system is owned
and operated by the Tuckaseigee Water and Sewer Authority (TOWASA), the regional authority in
Jackson County. The Cashiers WWTP plant capacity is 0.1 MGD and currently operates at 90
percent capacity. It discharges to a tributary of the Chatooga River designated by DWQ as B-Trout
and ORW (Outstanding Resource Waters). The WWTP's NPDES permit allows the facility to
expand to 0.2 MGD capacity with a concurrent reduction in effluent pollutant limits of 50 percent with
expansion (no increase in total maximum daily load or TMDL of regulated pollutants). The
classification of the receiving waters indicates that expanding the Cashiers WWTP beyond 0.2 MGD
at this location is unrealistic, for it would require costly upgrades to increase flows without increasing
TMDLs. For this reason, connecting to the Cashiers system was not considered further and a
detailed cost analysis was not prepared.
3.4. Connect to Franklin System.
The Town of Franklin is located along the Little Tennessee River 19 miles northwest of
Highlands. Under this option, the Highlands WWTP would be abandoned and its collection
system connected to the Franklin collection system.
There are numerous routes and methods of tying the Highlands collection system to the
Franklin WWTP. The most obvious route, the Highway 64/Culasaja River corridor, is highly
impractical and costly because of the 19-mile distance and mountainous terrain. The most
economical method of connecting the systems would be a new pumping station near the Highlands
WWTP and a new force main from Highlands to Franklin. The force main would follow existing
roads to minimize the need for private easements. The nearest segment of the Franklin collection
system is 14 miles from the Highlands WWTP.
4

residences and 25 vacant lots; 4) Mountain LaureVDog Mountain/NC-106 North area (107 acres
southwest of Highlands) containing 46 residences and 38 vacant lots; and 5) Flat Mountain area
(42 acres northwest of Highlands) containing 22 residences and 2 vacant lots. Highlands is also
negotiating to provide sewer service to Wildcat Cliffs Country Club and Cullasja Club, both
outside of town. Some of these areas currently use individual septic systems and others rely on
package WWTPs discharging in the Lake Sequoyah watershed.
Assuming 100 gallons of wastewater per capita per day (combined residential and non-
residential flows), the projected peak month average flow for the present Highlands town limits in
2025 is 1.44 MGD. An additional 0.07 MGD is added for the Highlands -Cashiers Hospital, which
includes the current 0.05 MGD plus 0.02 MDG for future expansion. The proposed annexation
areas would yield another 0.12 MGD, which brings the total projected 2025 peak month average
flow to 1.62 MGD. The proposed expansion to 1.5 MGD is based on the average of this
population -based projection and an alternative projection of 1.36 MGD based on WWTP flow
data.
3.0. ALTERNATIVES ANALYSIS.
The alternatives analysis presented here follows the alternatives discussed in the
Preliminary Engineering Report (PER) submitted with the 201 Plan.
3.1. No Action Alternative.
The no action alternative would prohibit the Town of Highlands from providing sewer service
to new customers within its existing limits as well as those in potential annexation areas. The
problem of failing septic systems in unsewered areas may worsen as these systems age, and
existing package treatment plants incapable of advanced treated will continue to Toad excess
nutrients and chlorine into small tributaries of Mirror Lake and Lake Sequoyah. Excess nutrients and
bacteria leached into surface and ground waters can be hazardous to public health, fish nursery
areas, and other environmentally sensitive areas. New development will have to rely on new on -site
treatment systems or package WWTPs. Some areas may be impractical to develop without
centralized sewer, thus limiting the economic potential for landowners and the Town's tax base. No
action is not considered a viable option and is eliminated from further consideration.
3.2. Spray Irrigation of Treatment Plant Effluent.
A suitable area, publicly or privately owned, should be located within one mile of the
treatment plant. Because of the low elevation of the treatment plant, a static head of 100 feet is
assumed. Regulations do not require storage because spray irrigation would be used in
combination with stream discharge. Tertiary filtration will be required for reuse of the effluent.
We assume that the spray irrigation system would be sized to discharge one third of the
projected 1.5 MGD capacity. Discharging 0.5 MGD through spray irrigation would require an
additional 0.5 MGD beyond the currently permitted 0.5 MGD to be discharged into the Cullasaja
River. Typical ranges of spray application rates for western North Carolina soils range from 0.5 to
1.75 inches per acre per week. An application rate of 1.5 inches per acre per week was assumed
for this evaluation but yields a smaller spray field area requirement than lower application rates. A
3

package treatment plants. Septic system failures are common in some areas, and several package
WWTPs in the area have been cited for repeated permit violations.
The goal of this WWTP expansion is to protect the Lake Sequoyah watershed by
connecting as much existing development as possible to the Highlands sewer system, eliminating
septic systems and package WWTPs to the extent practicable. The proposed expansion is sized to
accommodate full build -out of currently platted lots in the proposed wastewater service area. It will
not have excess capacity to accommodate new subdivisions. Need for retirement of septic systems
and package WWTPs in the watershed is further discussed in a 23 October 2002 letter from
Richard Betz, Highlands Town Clerk, included in Appendix E.
The Town is already working to reduce inflow and infiltration to the sewer system. During
late 1999 the WWTP began to experience sharply increased inflow. In April 2000 the average daily
flow was 0.25 MGD and peak daily flows was 0.51 MGD, exceeding the plant's 0.50 MGD capacity.
The system was repaired in May 2000, and in June 2000 average daily flows was 0.17 MGD and
peak daily flow was 0.22 MGD.
2.2. Population Growth and Flow Projections.
Several factors will increase wastewater flow to the Highlands WWTP:
1) extension of sewer service to Town residents that now use on -site treatment systems; 2) new
development within Town limits; 3) annexation of peripheral unincorporated areas with existing
subdivisions; and 4) new development in the areas to be annexed. The present Town limits
comprise 4,000 acres, and the five peripheral areas under study for annexation total 1,100 acres.
Most of the service area is in Macon County, but the easternmost portion of Highlands includes 400
acres in Jackson County. Existing and projected population served and wastewater flows are
described in the Preliminary Engineering Report (W.K.Dickson & Company, 2001) and summarized
below.
Highlands has seasonal population fluctuations associated with its tourism -dependent
economy. Summer and fall are the peak tourism seasons. WWTP flow data indicate that July is
usually the peak flow month. The Town's 2001 estimated permanent resident population is 1,152
persons, and the estimated seasonal resident population (in summer homes) is 4,637. Hotel and
motel rooms in Highlands add another 900 transients. Thus, the total population of permanent
residents, seasonal summer home residents, and transients during peak season is 6,689 persons.
In 2000 Highlands had 2,219 customers that receive public water but not public sewer. During the
past two years some of these have been connected to sewer.
Population and wastewater flow projections for the current Town limits are based on 1.79
percent annual growth of the permanent resident population, 3.93 percent annual growth of the
seasonal resident population, and no change in the transient (hotel/motel) population. Assuming
that 50 percent of existing residences using on -site wastewater systems will connect to public
sewer as the collection system expands, and all new development in Town will be built with sewer,
the projected peak month service population in 2025 is 14,360 people, without further annexation.
Projections for new development are based on undeveloped platted lots within existing
subdivisions. No allocation for new development outside of existing subdivisions was included.
Five areas are under study for annexation: 1) Hicks Road/Billy Cabin Road/Zachary Road
area (360 acres north of Highlands) containing 144 residences and 79 vacant lots; 2) Highlands
Falls Country C!=_'b area (540 acres northeast of Highlands) containing 301 residential lots; 3)
Ponderosa . ..ision/NC-106 South area (85 acres southwest of ' ids) containing 25
2

1.0. PROPOSED PROJECT DESCRIPTION.
The Town of Highlands in southeastern Macon County (Figure 1) proposes to expand its
existing municipal wastewater treatment plant (WWTP} from 0.5 million gallons per day (MGD) to
1.5 MGD to meet the anticipated peak month average flow in 2025. The effluent will continue to
be discharged via the existing outfall (NPDES Permit No. NC0021407) to the Cullasaja River just
below Lake Sequoyah dam. The expanded WWTP will have biological nutrient removal and dual
train treatment for the major treatment components (Figure 2). The facilities to be added include:
0.25 MGD sequencing batch reactor, 0.75 MGD sequencing batch reactor, two 0.078 MGD
aerobic digesters, 0.162 MGD post -equalization tank, ultraviolet disinfection, aerated digester,
maintenance and sludge condition building, sludge belt press, and emergency back-up generator.
All new construction will be on the existing WWTP property, which was cleared in 1994 (project
area). Effluent nitrogen and phosphorus concentrations will be reduced, and residual chlorine
eliminated. These proposed improvements will exceed the level of treatment needed to meet the
speculative NPDES effluent limits provided by N.C. Division of Water Quality (DWQ) in a 14
August 2002 letter (Appendix D).
Highlands also plans to install approximately 67,000 linear feet of new sanitary sewerlines
that will connect several existing neighborhoods and partially developed subdivisions within and
outside the Town to the expanded WWTP. These sewerlines will facilitate retirement of several
package WWTPs and hundreds of septic systems in the Lake Sequoyah watershed.
2.0. NEED FOR THE PROJECT.
2.1. Project History and Existing Facilities.
Until 1994 Highlands operated a 0.25 MGD WWTP that discharged to Mill Creek, a
headwater tributary upstream of Mirror Lake and Lake Sequoyah. These two lakes (Class WS-III-
CA-Tr) have extensive shoreline development built prior to the NC Water Supply Watershed
Protection Act, and had high nutrient loading rates due to the combination of fertilizer runoff and
wastewater effluent. Limnological studies by DWQ during the 1980s and early 1990s revealed
eutrophic conditions and anoxic bottom waters in these lakes. Consequently, in 1994 the Town
built a new 0.50 MGD WWTP discharging to the Cullasaja River just below Lake Sequoyah Dam
(Class B-Tr), and retired the old Mill Creek WWTP. The trophic state of Lake Sequoyah has
subsequently improved from eutrophic to mesotrophic, and its use support status has improved
from "support threatened" in 1994 to "supporting" in 1999.
The existing 0.5 MGD Highlands WWTP uses a sequencing batch reactor process. Existing
treatment facilities include two 217,000 gallon reactor tanks, one 81,000 gallon post equalization
tank, one 78,000 gallon aerobic digester, mechanically cleaned bar screen, chlorine gas contact
basin, sulfur dioxide dechlorination, chemical feed building, vacuum sludge dewatering bed, and
cascade aerator. The existing WWTP does not include biological nutrient removal.
The existing wastewater collection system consists of a gravity interceptor and four lateral
collectors serving the downtown area, Fourth Street, Upper Lake Road, Bear Pen Road, Pierson
Drive, and Satulah Road. A pump station at the old Mill Creek WWTP site and another on the
Monger Creek arm of Lake Sequoyah at NC-106 near Highlands Country Club convey all
wastewater to the WWTP. The sewer system presently serves only a small portion of the town.
Many residence 3r:=a businesses within and outside the town rely on privr.'s :Iptic systems or
1

ABBREVIATIONS USED IN THIS REPORT
cfs cubic feet per second (flow)
MGD million gallons per day (1.00 MGD = 1.55 cfs)
gpm gallons per minute (1.00 MGD = 694 gpm)
7Q10 7-day duration, 10-year frequency low stream flow
WTP water treatment plant
WWTP wastewater treatment plant
BOD-5 5-day biochemical oxygen demand
TSI trophic state index
dbh tree diameter at breast height
ROW right-of-way
EPT Ephemeroptera, Plecoptera, Trichoptera insect orders (water quality indicators)
USGS U.S. Geological Survey
FWS U.S. Fish and Wildlife Service
ACOE U.S. Army Corps of Engineers
NRCS U.S. Natural Resource Conservation Service (= Soil Conservation Service)
RECD U.S. Rural Economic & Community Development (= Farmers Home Admin.)
DENR N.C. Department of Environment and Natural Resources
DWQ N.C. Division of Water Quality
DWR N.C. Division of Water Resources
DAQ N.C. Division of Air Quality
DLR N.C. Division of Land Resources
DSWC N.C. Division of Soil & Water Conservation
DCoR N.C. Division of Coastal Resources
DMF N.C. Division of Marine Fisheries
WRC N.C. Wildlife Resources Commission
DPR N.C. Division of Parks and Recreation
NHP N.C. Natural Heritage Program
DEH N.C. Department of Environmental Health
DOA N.C. Department of Agriculture
PCP N.C. Plant Conservation Program
MNS N.C. Museum of Natural Sciences
SHPO N.C. State Historic Preservation Office
DOT N.C. Department of Transportation
DMV N.C. Division of Motor Vehicles
CAMA Federal Coastal Area Management Act
404/401 Sections 404 and 401 of the Federal Clean Water Act
NW P Section 404 Nationwide Permit (ACOE)
GWQC Section 401 General Water Quality Certification (DWQ
v

A.12. Peregrine Falcon (Falco peregrinus). 46
A.13. Bachman's Sparrow (Aimophila aestivalis). 47
A.14. Olive -sided Flycatcher (Contopus cooper!). 47
A.15. Southern Appalachian Black -capped Chickadee (Poecile atricapilla practica). 47
A.16. Appalachian Bewick's Wren (Thryomanes bewickii altus) 47
A.17. Bog Turtle (Clemmys muhlenbergii). 48
A.18. Mole Salamander (Ambystoma talpoideum). 48
A.19. Longtail Salamander (Eurycea longicauda longicauda). 48
A.20. Four -toed Salamander (Hemidactylium scutatum) 48
A.21. Green Salamander (Aneides aeneus). 49
A.22. Hellbender (Cryptobranchus alleganiensis). 49
A.23. Little Tennessee Rosyside Dace (Clinostomus funduloides ssp). 49
A.24. Spotfin Chub (Cyprinella monacha). 50
A.25. Striped Shiner (Luxilus chrysocephalus) 50
A.26. Wounded Darter (Etheostoma vulneratum). 50
A.27. Olive Darter (Percina squamata). 50
A.28. Turquoise Darter (Etheostoma inscriptum). 51
A.29. Yellowfin Shiner (Notropis lutipinnis). 51
A.30. River Mussels (Seven Species). 51
A.31. Terrestrial Mollusks (Ten Species). 52
A.32. Rock Gnome Lichen (Gymnoderma lineare) 52
A.33. Liverworts (Three Species) 53
A.34. Mosses (Three Species) 53
A.35. Filmy -ferns (Three Species). 53
A.36. West Indian Dwarf Polypody (Grammitis nimbata) 53
A.37. Piratebush (Buckleya distichophylla). 54
A.38. Queen of the Prairie (Filipendulla rubra). 54
A.39. Fringed Gentian (Gentianopsis crinita). 54
A.40. Holy Grass (Hierochloe odorata). 54
A.41. Virginia Spirea (Spiraea virginiana) 54
A.42. Radford's Sedge (Carex radfordii). 55
A.43. Tall Larkspur (Delphinium exaltatum). 55
A.44. Swamp Pink (Helonias bullata). 55
A.45. Goldenseal (Hydrastis canadensis). 55
A.46. Small Whorled Pogonia (Isotria medeoloides). 56
A.47. Fraser's Loosestrife (Lysimachia fraseri). 56
A.48. Divided -leaf Ragwort (Senecio miiiefolium). 56
A.49. Prairie Dropseed (Sporobolus heterolepis). 56
A.50. Mottled Trillium (Trillium discolor). 57
Appendix B. Agency Scoping Comments.
Appendix C. Public Scoping Comments and Public Meeting Minutes and Affidavit of Publication.
Appendix D. Speculative Effluent Limits for the Highlands WWTP Expansion.
Appendix E. EA Review Comments and Responses.
Iv

5.10. WILDLIFE AND TERRESTRIAL HABITAT IMPACTS. 21
5.11. FORESTRY RESOURCE IMPACTS 21
5.12. JURISDICTIONAL WETLAND IMPACTS 22
5.13. PROTECTED SPECIES IMPACTS. 22
5.14. INTRODUCTION OF TOXIC SUBSTANCES. 23
6.0. MITIGATIVE MEASURES 23
6.1. MITIGATION FOR DIRECT IMPACTS. 23
6.2. MITIGATION FOR INDIRECT AND CUMULATIVE IMPACTS 24
6.2.1. Zoning and Watershed Ordinance. 24
6.2.2. Subdivision Ordinance. 25
6.2.3. Soil Erosion and Sedimentation Control Ordinance 26
6.2.4. Ordinance Regulating the Draining of Impoundments. 27
6.2.5. Lake Ordinance and Reservoir Recreation Plan. 28
6.2.6. Other Water Quality Protection Measures. 28
7.0. STATE AND FEDERAL PERMITS REQUIRED 29
8.0. LITERATURE CITED 30
9.0. QUALIFICATIONS OF PREPARERS 32
TABLE 1. AMBIENT AIR QUALITY DURING 1998-99 IN THE VICINITY OF MACON COUNTY NC. 34
TABLE 2. SITE INDICES FOR TIMBER PRODUCTION ON SOILS IN MACON COUNTY, NC 35
TABLE 3. JURISDICTIONAL WETLAND IMPACTS IN THE PROJECT AREA. 36
TABLE 4. STREAM IMPACTS IN THE PROJECT AREA. 36
TABLE 5. PROTECTED SPECIES KNOWN FROM MACON COUNTY, NC. 37
FIGURE 1. TOWN OF HIGHLANDS WWTP SITE AND WASTEWATER SERVICE AREA. 39
FIGURE 2. SITE PLAN OF PROPOSED HIGHLANDS WWTP IMPROVEMENTS. 40
FIGURE 3. DWQ SURFACE WATER CLASSIFICATIONS IN HIGHLANDS AND SURROUNDING AREA. 41
FIGURE 4. PROTECTED WATER SUPPLY WATERSHEDS IN THE HIGHLANDS SERVICE AREA. 42
FIGURE 5. STREAM AND WETLAND IMPACTS IN THE PROPOSED SEWERLINE CORRIDORS. 43
Appendix A. Protected Species Descriptions, Habitat, and Likelihood in the Project Area.
A.1. Rafinesque's Big -eared Bat (Corynorhinus rafinesquii). 44
A.2. Northern Long-eared Bat (Myotis septentrionalis). 44
A.3. Indiana Bat (Myotis sodalis). 44
A.4. Carolina Northern Flying Squirrel (Glaucomys sabrinus coloratus). 45
A.5. Eastern Woodrat (Neotoma floridana haematoreia) 45
A.6. Southern Rock Vole (Microtus Chrotorrhinus carolinensis). 45
A.7. Long-tailed Shrew (Sorex dispar). 45
A.8. Southern Water Shrew (Sorex palustris punctulatus). 45
A.9. Southern Pygmy Shrew (Sorex hoyi winnemana) 46
A.10. Southern Appalachian Saw -whet Owl (Aegolius acadicus). 46
A.11. Cooper's Hawk (Accipiter cooperii). 46
III

TABLE OF CONTENTS
1.0. PROPOSED PROJECT DESCRIPTION. 1
2.0. NEED FOR THE PROJECT. 1
2.1. PROJECT HISTORY AND EXISTING FACILITIES. 1
2.2. POPULATION GROWTH AND FLOW PROJECTIONS. 2
3.0. ALTERNATIVES ANALYSIS. 3
3.1. NO ACTION ALTERNATIVE. 3
3.2. SPRAY IRRIGATION OF TREATMENT PLANT EFFLUENT. 3
3.3. CONNECT TO CASHIERS SYSTEM. 4
3.4. CONNECT TO FRANKLIN SYSTEM. 4
3.5. ON -SITE WASTEWATER SYSTEM FOR TREATMENT PLANT EFFLUENT 5
3.6. EXPAND HIGHLANDS WWTP AND STREAM DISCHARGE (PREFERRED ALT). 5
3.7. ADDITIONAL CONSIDERATIONS. 6
4.0. EXISTING ENVIRONMENT. 7
4.1. TOPOGRAPHY AND SOILS 7
4.2. LAND USE. 7
4.3. PRIME AND UNIQUE FARMLANDS. 8
4.4. PUBLIC, SCENIC, AND RECREATIONAL AREAS. 8
4.5. ARCHAEOLOGICAL AND HISTORIC RESOURCES. 8
4.6. AIR QUALITY. 8
4.7. NOISE LEVELS. 9
4.8. WATER RESOURCES. 9
4.8.1. Surface Water Hydrology. 9
4.8.2. Surface Water Usage Classifications. 10
4.8.3. Existing Surface Water Quality. 11
4.8.3.1. Cullasaja River Above Lake Sequoyah. 11
4.8.3.2. Lake Sequoyah. 12
4.8.3.3. Cullasaja River Below Lake Sequoyah 12
4.8.4. Groundwater Resources. 14
4.9. FISH AND AQUATIC HABITATS. 14
4.10. WILDLIFE AND TERRESTRIAL HABITATS. 15
4.11. FORESTRY RESOURCES. 15
4.12. JURISDICTIONAL WETLANDS AND WATERS. 16
4.13. PROTECTED SPECIES. 16
5.0. PREDICTED ENVIRONMENTAL IMPACTS. 17
5.1. TOPOGRAPHY AND SOIL IMPACTS. 17
5.2. LAND USE IMPACTS. 18
5.3. PRIME AND UNIQUE FARMLANDS IMPACTS. 18
5.4. PUBLIC, SCENIC, AND RECREATIONAL AREAS IMPACTS. 19
5.5. ARCHAEOLOGICAL AND HISTORIC RESOURCES IMPACTS 19
5.6. AIR QUALITY IMPACTS. 19
5.7. NOISE LEVEL IMPACTS 19
5.8. WATER RESOURCES IMPACTS 20
5.9. FISH AND AQUATIC HABITAT IMPACTS. 21
11

ENVIRONMENTAL ASSESSMENT
FOR 201 FACILITIES PLAN AMENDMENT
TOWN OF HIGHLANDS
WASTEWATER TREATMENT PLANT EXPANSION
MACON COUNTY, NORTH CAROLINA
State Clearinghouse Review Number 02E-4300-0307
NC DENR Review Number 1204
May 2002 - First Draft EA for Lead Agency Review
26 August 2002 - Second Draft EA for DENR Review
19 February 2003 - Third Draft EA for DENR Review
10 September 2003 - Final EA for Clearinghouse Review
Lead Agency Contact:
Mr. Alex Marks
N.C. Division of Water Quality
1617 Mail Service Center
Raleigh, N.C. 27699-1617
[phone] ext 555
Municipal Contact:
Mr. Richard Betz
Highlands Town Administrator
P.O. Box 460
Highlands, NC 28741
[phone]
Project Engineer:
Mr. Michael Osborne, P.E.
W.K. Dickson & Company
616 Colonnade Drive
Charlotte, NC 28205
[phone]
Prepared By:
Robert J. Goldstein & Associates, Inc.
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive
Raleigh, North Carolina 27616-3175
Tel [phone] Fax [phone]
www.riciaCarolina.com
RJG&A Project 2154

1N A T Michael F. Easley, Govemor
�9Q William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
7 Alan W. Klimek, P.E. Director
Division of Water Quality
April 15, 2003
Mr. Gerald Pottern
Robert J. Goldstein and Associates, Inc
8480 Garvey Drive
Raleigh, North Carolina 27616
Subject: Highlands WWTP Expansion Environmental Assessment
Dear Mr. Pottern:
Comments from the NC Wildlife Resource Commission (WRC) and the NC Division of Water Quality's
NPDES Unit (DWQ) regarding the subject environmental document are attached. Please contact Mr. Owen
Anderson with WRC at [phone] ext. 24 and Ms. Susan Wilson with DWQ at [phone] ext. 510 to
resolve their concerns.
You may wish to arrange a meeting with either Mr. Anderson or Ms. Wilson to discuss specific issues.
Additionally, please copy me on any written correspondence that is provided in response to either of their
comments.
If you have any questions, please contact me at [phone] ext. 555.
Sincerely,
Alex k , AICP
Environmental
�, n al Specialist
Attachments
CC: Owen Anderson, WRC (w/o att.)
Susan Wilson, DWQ (w/o att.)
AVA
NICOENR
N. C. Division of Water Quality 1617 Mall Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748

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