NC0021407_Environmental Assessment_20030225

NPDES DOCIMENT SCANNIN`: COVER SHEET
NC0021407
Highlands WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Instream Assessment (67b)
Speculative Limits
Environmental Assessment EA))
Document Date:
February 25, 2003
This document is printed on reuse paper - ignore any
content on the reverse side

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ENVIRONMENTAL ASSESSMENT
FOR 201 FACILITIES PLAp AMENDMENT
TO OF GHLANDS /VoU 2/ L/O v)
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 - Final EA for Clearinghouse Review
Lead Agency Contact:
Mr. J. Todd Kennedy
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]
Prepared By:
S
F E B 2 5 2003
DENR - WATER QUALITY
POINT SOURCE BRANCH
Project Engineer:
Mr. Michael Osbome, P.E.
W.K. Dickson & Company
616 Colonnade Drive
Charlotte, NC 28205
[phone]
Robert J. Goldstein & Associates, Inc.
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive
Raleigh, North Carolina 27616-3175
Tel [phone] Fax [phone]
www.ridaCarolina.com
RJG&A Project 2154

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

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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 AREA41
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. Southem Pygmy Shrew (Sorex hoyi winnemana). 46
A.10. Southem Appalachian Saw -whet Owl (Aegolius acadicus). 46
A.11. Cooper's Hawk (Accipiter cooperii). 46
III

A.12. Peregrine Falcon (Falco peregrinus). 46
A.13. Bachman's Sparrow (Aimophila aestivalis). 47
A.14. Olive -sided Flycatcher (Contopus coopen). 47
A.15. Southern Appalachian Black -capped Chickadee (Poecile atricapilla practice) 47
47
A.16. Appalachian Bewick's Wren (Thryomanes bewickii altus). 48
A.17. Bog Turtle (Clemmys muhlenbergil). 48
A.18. Mole Salamander (Ambysfoma talpoideum)
A.19. Longtail Salamander (Eurycea longicauda longicauda) 48
48
A.20. Four -toed Salamander (Hemidactylium scutatum).
A.21. Green Salamander (Aneides aeneus). 49
A.22. He!lbender (Cryptobranchus alleganiensis) 49
A.23. Little Tennessee Rosyside Dace (Clinostomus funduloides ssp) 49
A.24. Sporn 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 linear). 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 disfichophylla). 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 (Helonlas bullata). 55
A.45. Goldenseal (Hydrastis canadensis) 55
A.46. Small Whorled Pogonia (lsotria medeoloides) 56
A.47. Fraser's Loosestrife (Lysimachia fraseri) 56
A.48. Divided -leaf Ragwort (Senecio millefolium). 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 VWVfP Expansion.
Appendix E. EA Review Comments and Responses.
IV

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
VWVTP 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
NWP Section 404 Nationwide Permit (ACOE)
GWQC Section 401 General Water Quality Certification (DWQ
v

1.0. PROPOSED PROJECT DESCRIPTION.
The Town of Highlands in southeastem 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 VVWTP 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 WVVTP 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 VWVfPs 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 WVVTP 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 VWVTP. 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 WVVTP 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 dechiorination, 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 WVVTP 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 residences and businesses within and outside the town rely on private septic systems or
1

package treatment plants. Septic system failures are common in some areas, and several package
VWVTPs in the area have been cited for repeated permit violations.
The goal of this WVVTP 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 WVVTPs to the extent practicable. The proposed expansion is sized to
accommodate full build -out of currently platted Tots in the proposed wastewater service area. It will
not have excess capacity to accommodate new subdivisions. Need for retirement of septic systems
and package WVVTPs 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 WVVTP 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 eastemmost 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. VWVTP 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 (hoteVmotel) 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 Tots; 2) Highlands
Falls Country Club area (540 acres northeast of Highlands) containing 300 residential lots; 3)
Ponderosa Subdivision/NC-106 South area (85 acres southwest of Highlands) containing 25
2

residences and 25 vacant Tots; 4) Mountain Laurel/Dog Mountain/NC-106 North area (107 acres
southwest of Highlands) containing 46 residences and 38 vacant Tots; 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 VWVrPs 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 altemative projection of 1.36 MGD based on WWTP flow
data.
3.0. ALTERNATIVES ANALYSIS.
The altematives 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 VWVTPs. 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

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 VWVfP would be abandoned and the Highlands collection system would be
connected to the Cashiers collection system. The Cashiers VWVfP 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 WVVfP'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 VWVTP. 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 VWVfP.
4

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 VWVrP 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 VVVVfP 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

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-govemmental 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 VViId 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 chronic adverse events such as the release of toxic substances or excessive nutrients.
6

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 VW TP 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 VWVTP expansion is within the existing fence, and was cleared and
graded when the original VVWTP 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 tourism as the principal commercial development. There is no heavy
7

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 southem 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 has continued, with only 39 of 526 samples above minimum detection levels (DAQ,
8

2001). Air quality standards are based on hourly, daily, quarterly, or annual averages, depending
on each pollutants 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, lying 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 mapped by USGS in the project service area. The Soil Survey of Macon County
9

(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 B watershed, mostly in the Chattooga River basin.
10

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 dose 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 1990 and 1999 (NC Division of Water Quality, 2000) and
fish community sampling by Dr. William McLamey. Mill Creek, which flows through downtown
Highlands, was rated fair both above and below the old VWVfP 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 reduce impacts 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 Togs 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) develop local regulations to control development on steep slopes and
11

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 WVVTP on Mill Creek
upstream of Mirror Lake, and replace it in 1994 with the current 0.50 MGD WVVTP 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 15Ng/1 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 WVVfP 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 VWVI'P discharge is estimated at 7.2 cfs, based on the new gage and historic flow
12

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 WVVTP 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. McLamey 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 McLamey, 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, P, 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
southem Swain County (Dr. William McLamey, personal communication). Apparently healthy
populations of several federal and state protected fishes and mussels occur in this river segment,
species extirpated from most other streams in their historic range. Despite the discrepancy in
13

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 McLamey, personal communication).
Typical fishes in the Cullasaja River and tributaries between Dry Falls and Franklin include
the mountain brook lamprey (Ichthyomyzon greeleyi), native brook trout (Salvelinus fontinalis),
western rainbow trout (Oncorhynchus mykiss), exotic brown trout (Salmo 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 (Hypentelium 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 (Coitus bairn;), 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 (Clinostomus funduloides.), wounded darter (Etheostoma
vulneratum), and olive darter (Percina squamata), based on Menhinick and Braswell (1997). The
helibender (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

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 southem and eastem 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 VVWTP construction area is within the VWVfP fence, and was cleared and
graded during construction of the original VWVfP in 1994. It is urban land with negligible vegetation
or wildlife habitat value. Animals likely to occur on the VVWTP property are limited to those that
tolerate urban and rural areas, including the five -lined skink (Eumeces fasciatus), Fowler's toad
(Bufo woodhousel), gray treefrog (Hyla chrysoscelis), house sparrow (Passer domesticus), cardinal
(Cardinalis 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 VVWTP 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 VVWTP
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 VW TP 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 WVVfP fence and in the wastewater service area are described
15

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 VWVTP 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 outran
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, leucothoe, 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 concem (SC). Rare
species under consideration for future legal protection are designated as candidate (C), federal
species of concem (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.
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The Highlands area is geologically, topographically, and ecologically unique, even within the
context of the regionally unique southem 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 concem. These protected
species are listed in Table 3 with their corresponding federal and state protection status and habitat
req
uirements. uirements. 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 VWVfP 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 WVVfP 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
WVVTPs) 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 WVVTP 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 impactscolumnof
Table 3, and could be subject to impacts of future development supported by the
expansion.
5.0. PREDICTED ENVIRONMENTAL IMPACTS.
5.1. Topography and Soil Impacts.
VWVfP expansion will occur on approximately five acres entirely within the existing
WVVTP 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

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 Toss 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 WVVTPs 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 Tots 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 westem portion (932 acres) including Lake Sequoyah, Big Creek, and the westem 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 southem and eastem 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 WVVTP 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.
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5.4. Public, Scenic, and Recreational Areas Impacts.
No public, scenic, or recreational areas occur in the VWVTP construction area, and no
direct impacts will occur. The expanded VWVfP 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 airbome 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 buming 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.
Airbome particulates may temporarily increase near the VWVfP 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 rural areas that are presently relatively quiet. Careful planning and
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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 VWVfP 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 VWVTP 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 VWVfP improvements will allow future expansion of the Town's wastewater collection
system to unsewered areas, and subsequent retirement of older septic systems and package
VWVfPs that lack 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 VWVfP 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
VV TP 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.
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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 VWVfP 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 VWVfP due to the proposed treatment process
improvements, which include nutrient removal and UV disinfection. Retirement of malfunctioning
septic systems and package WVVTPs 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 southem 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 VWVfP 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 VWVfP 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.
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5.12. Jurisdictional Wetland Impacts.
No ACOE jurisdictional are present on the WWfP 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 loss. 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 WVVfP 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 WVVTP 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).
22

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 VWVfP 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 VWVI'P facilities will be built on previously cleared land containing no
woodland, wetlands, or streams, and construction will comply with Highlands' stringent Erosion and
23

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 VWVfP, and several existing package VWVTPs 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 VVWTP expansion is primirily 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. 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-BVV), 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 unit per two acres. Cluster and multi -family developments allow
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
24

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 proposed streets outside the Town's planning area must be
accompanied by a letter of approval from the District Engineer of NCDOT. Sanitary sewer and
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
25

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 Tying 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 Sedimentation Control Ordinance mandates buffer zones along
lakes and watercourses. The Town enforces the N.C. Environmental Management Commission's
(EMC's) 25-foot buffers adjacent to waters designated as Trout waters and further requires that
26

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 included.
27

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 VWVfP (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 of the 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

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
VVWTP, 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

8.0. LITERATURE CITED
Adams, W.F., J.M. Alderman, R.G. Biggins, A.G. Gerberisch, E.P. Keferl, H.J. Porter, and
A.S. VanDevender. 1990. A report on the conservation status of North Carolina's freshwater and
terrestrial molluscan fauna. The Scientific Council on Freshwater and Terrestrial Mollusks, Raleigh,
N.C. 246 pp.
Amoroso, J.L. 1999. Natural Heritage Program List of the Rare Plant Species of North
Carolina. North Carolina Natural Heritage Program, Division of Parks and Recreation. N.C.
Department of Environment, Health, and Natural Resources. 85 pp.
Claytor, R.A. 1995. Assessing the potential for urban watershed restoration. Watershed
Protection Techniques 1(4): 165-172.
Daniel, C.C. III and R.A. Payne. 1990. Hydrogeologic map of the Piedmont and Blue Ridge
Provinces of North Carolina. U.S. Geological Survey Water Resources Investigations Report 90-
4035, Raleigh, N.C. 1 p.
Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual,
Technical Report Y-87-1. U.S. Army Engineer Waterways Experiment Station, Vicksburg, Miss.
100 p. + appendices.
Fernald, M.L. 1950. Gray's Manual of Botany. Dioscorides Press, Portland, Oregon. 1632
pp.
Fish, F. F. 1969. Catalog of the Inland Fishing Waters of North Carolina. North Carolina
Wildlife Resources Commission, Raleigh, N.C. 188 pp.
Hooper, Robert G., Andrew F. Robinson, Jr. and Jerome A. Jackson. 1980. The red -
cockaded woodpecker notes on life history and management. USDA Forest Service,
Southeastern Area. General Report SA-GR 9.
LeGrand, H.E. Jr. 1987. Inventory of the Natural Areas of Wake County, North Carolina.
Triangle Land Conservancy and N.C. Natural Heritage Program, N.C. Department of Environment,
Health, and Natural Resources, Raleigh, N.C. 161 pp.
Lee, D.S., J.B. Funderburg, Jr., and M.K. Clark. 1982. A distributional survey of North
Carolina mammals. Occasional Papers of the N.C. Biological Survey, 1982-10. 70 pp.
LeGrand, H.E. Jr. and S.P. Hall, 1999. Natural Heritage Program list of the rare animal
species of North Carolina. N.C. Natural Heritage Program, Division of Parks and Recreation,
Raleigh. 91 pp.
Martof, B.S., W.M. Palmer, J.R. Bailey, and J.R. Harrison III, 1980. Amphibians and Reptiles
of the Carolinas and Virginia. Univ of North Carolina Press, Chapel Hill, N.C. 264 pp.
Menhinick, E.F. 1991. The Freshwater Fishes of North Carolina. N.C. Wildlife Resources
Commission, Raleigh, N.C. 227 pp.
30

Menhinick, E.F. and A.L. Braswell. 1997. Endangered, Threatened, and Rare Fauna of
North Carolina, Part IV: A Re-evaluation of the Freshwater Fishes. N.C. Museum of Natural
Sciences, Raleigh, N.C. 106 pp.
NatureServe Explorer An online encyclopedia of life [web application]. 2001. Version 1.6 .
Arlington, Virginia, USA: NatureServe. Available: http://www.natureserve.org/explorer. (Accessed:
February 27, 2002 ).
N.C. Division of Air Quality. 2000. 1998 Ambient Air Quality Report. Department of
Environment and Natural Resources, Raleigh. 76 pp.
N.C. Division of Land Resources. 1985. Geologic map of North Carolina. N.C. Dept of
Natural Resources and Community Development - Geological Survey, Raleigh. 1 p.
Potter, E.F., J.F. Pamell, and R.P. Teulings. 1980. Birds of the Carolinas. University of
North Carolina Press. Chapel Hill, N.C. 408 pp.
Radford, A.E., H.E. Ahles, and C.R. Bell, 1968. Manual of the Vascular Flora of the
Carolinas. University of North Carolina Press, Chapel Hill, N.C. 1,183 pp.
Robbins, C.S., B. Bruun, and H.S. Zim. Birds of North America. Golden Press, New York,
N.Y. 340 pp.
Schafale, M.P. and A.S. Weakley. 1990. Classification of the Natural Communities of North
Carolina - Third Approximation. North Carolina Natural Heritage Program, Division of Parks and
Recreation, Raleigh, N.C. 325 pp.
Schueler, T.R. 1995. Architecture of urban stream buffers. Watershed Protection
Techniques 1(4): 155-165.
Thomas, D.J. 1996. Soil survey of Macon County, North Carolina. U.S. Department of
Agriculture, Natural Resources Conservation Service, Raleigh, N.C. 322 p. + maps.
Town of Highlands, December 5, 2001. Zoning Ordinance, with Amendments.
U.S. Environmental Protectional Agency. 1990. National air pollutant emission estimates,
1940-1988. EPA-450/4-90-001. 68 pp.
Weakley, Alan S., 2000. Flora of the Carolinas and Virginia, Working Draft of May 15, 2000.
Draft version, printed for RJG&A by permission of Alan S. Weakley.
Webster, W.D., J.F. Parnell, and W.C. Biggs, Jr. 1985. Mammals of the Carolinas, Virginia,
and Maryland. University of North Carolina Press, Chapel Hill, N.C. 255 pp.
31

9.0. QUALIFICATIONS OF PREPARERS
Robert J. Goldstein, Ph.D. is the project manager. Dr. Goldstein established RJG&A in
1985, and has managed all environmental studies, negotiations and implementation of mitigation
plans. He has provided expert witness testimony and he has prepared environmental documents
assessing impacts of construction projects on inland and coastal waters and wetlands, fisheries,
and sea turtles as mandated by Sections 316, 401, and 404 of the Clean Water Act, and by the
federal Endangered Species Act. He has conducted Phase I environmental site assessment
(hazardous waste) investigations subject to RCRA, CERCLA, and the N.C. Petroleum Act, and
prepared environmental documents following Fannie Mae, RTC, and ASTM guidelines. He
served on the Habitat and Environmental Protection Advisory Panel of the South Atlantic
Fisheries Management Council as Chairman of the North Carolina delegation.
Gerald B. Pottern, M.Sc. is RJG&A's senior biologist, aquatic ecologist, and wetland
delineator. He has completed COE's WET 2.0 wetland evaluation course and a COE-authorized
Wetland Delineator Certification Training course, and is awaiting certification as a professional
wetland scientist from the Society of Wetland Scientists. Under contract to U.S. Fish & Wildlife
Service he performed a status survey of the Cape Fear shiner and prepared documentation to
support its listing under the Endangered Species Act. His M.Sc. research on stream fish
assemblages produced an Index of Biotic Integrity applicable to North Carolina streams. Since
1986 he has conducted surveys for protected mussels, fishes, terrestrial vertebrates, and plants.
He has conducted wetland delineation and functional assessments, environmental assessments,
and prepared compensatory mitigation plans.
Christopher Hopper, B.Sc. is RJG&A's forester and GPS/GIS specialist. Mr. Hopper
conducts terrestrial habitat inventories, protected species surveys, and jurisdictional wetland
delineations. He manages and compiles field data, prepares mapping of natural resources,
quantifies impacts of the altematives, and assists in document preparation. Mr. Hopper prepares
ArcView and AutoCAD files of field investigation data for use by local govemments and project
design engineers.
H. Ward Marotti, B.Sc. is RJG&A's plant ecologist and mining specialist. He has
conducted rare species surveys, wetland delineations, functional condition assessments, and
habitat/resource inventories since 1992. He has authored numerous compensatory mitigation
plans, mine reclamation plans, and reclamation monitoring reports. Mr. Marotti has served as
technical lead for wetland delineation under contract to EPA on CERCLA and Superfund sites and
completed NRCS Hydric Soils for Wetland Delineation in July 2000. He has extensive experience
in aerial photo interpretation, GIS/GPS data analysis, and digital mapping. He has designed,
implemented, and managed Large- and small-scale ecological monitoring databases.
32

TABLES, FIGURES, AND APPENDICES
Table 1. Ambient Air Quality during 1998-99 in the Vicinity of Macon County,NCNC
Table 2. Site indices for Timber Production on Soils in Macon County,
Table 3. Jurisdictional Wetland Impacts in the Project Area
Table 4. Stream Impacts in the Project Area
Table 5. Protected Species known from Macon County, NC
Table 6. Significant Natural Areas within 1.5 miles of the Service Area
Figure 1. Town of Highlands VWVTP Site and Service Area, Including Annexation Areas
Figure 2. Site Plan of Proposed Highlands VWVfP Improvements
Figure 3. DWQ Surface Water Classifications in Highlands and Surrounding Area
Figure 4. Protected Water Supply Watershed Areas in the Highlands Service Area
Figures 5.0. - 5.3. Wetland and Stream Impacts Along Construction Corridors
Appendix A. Protected Species Descriptions, Habitat, and Likelihood in the Project Area.
Appendix B. Agency Scoping Comments.
Appendix C. Public Scoping Comments, Public Meeting Minutes and Affidavit of Publication.
Appendix D. Speculative Effluent Limits for the Highlands WWTP Expansion.
Appendix E. EA Review Comments and Responses.
33

Table 1.
Ambient Air Quality During 1998-99 in the Vicinity of Macon County NC.
Air Pollutant
Site: Number
of Samples
Total Suspended Particulates none
(TSP = 0 to 45 microns)
Particulate Matter -10 A: 53
(PM-10 = 0 to 10 microns)
none
Nitrogen Dioxide (NO2)
Sulfur Dioxide (S02)
Carbon Monoxide (CO)
Ozone (03)
N.C. Air Quality Standard
(and Period of Average)
annual geom. mean
24-hr 2nd maximum
annual arith. mean
24-hr 99th percentile
annual arith. mean
A : 7,869** annual arith. mean
24-hr 2nd maximum
3-hr 2nd maximum
none 8-hr 2nd maximum
1-hr 2nd maximum
B : 5,064
: 211
1-hr expect 2nd max
8-hr mean 4th max
75 ug/m3
150 ug/m3
50 ug/m3
150 ug/m3
0.053 ppm
0.03 ppm
0.14 ppm
0.5 ppm
9 ppm
35 ppm
0.124 ppm
0.08 ppm
Observed Maximum Value Observed
Value (and Period of Average)
22 ---
41 * 44 (24-hr)
MOD
0.005
0.008
0.018
0.107
0.096**
0.008 (24-hr)
0.028 (3-hr)
0.110 (1-hr)
0.098 (8-hr)
Site A = Site number 37-173-0002. Center Street, Parks 7 Rec. Facility, Swain County.
Site B = Site number 37-087-0035. Blue Ridge Parkway tower, mile marker 410. Haywood County.
* 24-hr 99 percentile data not tabulated by DAQ; approximated using 24-hr 2nd maximum.
1998 Ambient Air Quality monitoring data.
**

Table 2. Site Indicies for Timber Production on Soils in Macon County, NC
Soil Series
Tree Species
Chandler
CdF
Cleveland Chestnut
Complex
CpD CpE
Cullasaja - Tuckasegee
Complex
CuD
Edneyville-Chestnut Complex
EdC EdD EdE
Nikwasi
NkA
Black Oak
--
--
--
--
71
71
71
--
Chestnut Oak
67
40
40
--
69
69
69
--
Eastern White Pine
88
--
--
98
78
78
78
86
Hickory
--
--
--
--
Northern Red Oak
--
45
45
--
76
76
76
--
Pitch Pine
--
--
--
--
--
--
--
--
Red Maple
--
--
--
--
Scarlet Oak
--
--
--
--
68
68
68
--
Shorleaf Pine
--
--
--
64
--
--
--
Virginia Pine
--
--
--
--
66
--
--
--
White Oak
67
--
--
--
70
70
70
--
Yellow Poplar
--
--
--
109
97
97
97
88
Tree Species
Plott
PwD PwE PwF
Rock Outcrop -
Cleveland Complex
RkF
Toxaway
ToA
Tuckasegee -
Cullasaja
Complex
TsC
Tuckasegee -
Whiteside
Complex
TwC
Black Oak
-- -- --
--
--
Chestnut Oak
-- -- --
40
--
Eastern White Pine
-- -- --
--
94
98
98
Hickory
-- -- --
--
--
Northern Red Oak
85 85 85
--
--
Pitch Pine
-- -- --
--
__
Red Maple
-- -- --
--
_-
Scarlet Oak
-- -- --
--
Shorleaf Pine
-- -- --
--
__
Virginia Pine
-- -- --
--
--
White Oak
-- -- --
--
__
Yellow Poplar
113 113 113
--
85
109
109
e site index is the average height (in feet) of dominant and co -dominant canopy trees at 50 years.
Source: Thomas, 1996.

Table 3. Jurisdictional Wetland Impacts (Approximate).
Acres
A
CH
0.010
B
CH
0.017
E
CH
0.022
F
CH
0.002
G
CH
0.011
K
herb
0.001
R
herb
0.006
U
herb
0.002
nn.Vw
TOTAL
CH=Canada hemlock
herb=herbaceous
Table 4. Stream Impacts Along Project Construction Corridors.
Permanence Substrate Width (feet) Habitat
1
P
s,g,c
10
CH
2
P
s,g
6
CH/herb
3
P
s,g,b,br
15
CH
4
P
s,g
8
CH
" 5
1
s,g,Iv
5
CH
6
P
s,g
10
CH
7
P
s,g
5
CH
8
1
s,g
2
CH
9
1
s,g
3
CH
10
1
s,g
3
CH
11
P
s,g
10
CH
12
1
s
1
CH/0
13
P
s,g
15
CH
14
1
s,g
4
CH
15
P
s,g
10
CH/0
16
P
s,g
4
CH
17
P
s,g
4
CH
18
P
s,g,c
10
CH
19
P
s,g,c
8
CH
20
P
s,g,c,b,br
20
CH
21
P
s,g
8
CH
22
P
s,g,br
6
CH/herb
23
P
s,g,br
4
CH
24
P
s,g,br
4
CH
25
P
s,g
4
CH
26
P
s,g
5
herb
27
P
s,g
5
CH
28
P
s,g
5
CH
29
P
s,g,b,br
60
CH
30
P
s,g
5
CH
31
P
s,g
6
CH
32
P
s,g
10
CH/0
33
I
s,g
5
CH/0
34
I
s,g,c
5
CH/0
CH = Canada hemlock CH/0 = Canada hemlock/mixed oak
herb = herbaceous
lv = leaves s = sand g = gravel c = cobble b = boulder br = bedrock

Table 5. Protected Species from Macon County, NC - November 2001 1 of 4
Latin Name
MAMMALS
Corynorhinus rafinesquii
Common Name
HABITATS (Legrand and Hall, 1999)
Status Likelihood in
State Federal Service Area
Old buildings, hollow trees, caves, mines,
Rafinesque's Big -eared Bat under bridges, near water SC FSC 2
Glaucomys sabrinus coloratus
Carolina Northem Flying Squirrel High elevation forests, mainly Spruce -Fir E E 0
Microtus Chrotorrhinus carolinensis Southem Rock Vole
rocky areas at high elevations, forests or fields SC FSC 3
Myotis septentrionalis Northern Long-eared Bat
Myotis sodalis
Indiana Bat
active months: hollow trees and buildings,
hibernation: in caves and mines SC 2
roosts in hollow trees or under loose bark E E 2
Neotoma floridana haematoreia Eastem Woodrat
Sorex dispar Long-tailed Shrew
Sorex hoyi winnemana Southen Pygmy Shrew
Sorex palustris punctulatus Southem water shrew
rocky places in deciduous or mixed forests SC FSC 2
high elevation forests with talus or rocky
slopes SC 2
montane deciduous forests SC 2
stream banks in montane forests SC FSC 2
BIRDS
Accipiter cooperii
Cooper's Hawk
forests and woodlands
SC 2
Southern Appalachian Northern
Aegolius acadicus Saw whet Owl
Aimophila aestivalis Bachman's Sparrow
Contopus cooped Olive -sided Flycatcher
Falco peregrinus
Poecile atricapilla practica
Peregrine Falcon
Southem Appalachian Black -
capped Chickadee
Thryomanes bewickil anus Appalachian Bewick's Wren
spruce -fir forests or mixed hardwood/spruce
forests
open longleaf pine forests, old fields
montane conifer forests (spruce/fir) with
openings or dead trees (breeding)
SC FSC 2
SC FSC 2
SC FSC 2
cliffs(nesting); coastal ponds and mudflats
(winter foraging) E 2
high elevation forests, mainly spruce fir
(breeding) SC FSC 2
woodland borders or openings, farmlands or
brushy fields at high elevations E FSC 2

Table 5. Protected Species from Macon County, NC - November 2001 2 of 4
Latin Name Common Name HABITATS (Legrand and Hall, 1999) Status Likelihood in
State Federal Service Area
AMPHIBIANS & REPTILES
Ambystoma talpoideum
Aneides aeneus
Clemmys muhlenbergii
Cryptobranchus alleganiensis
Eurycea longicauda longicauda
Hemidactylium scutatum
fish -free semi -permanent woodland ponds
Mole Salamander (breeding); adjacent woods (foraging) SC 2
damp, shaded crevices of cliffs or rock
Green Salamander outcrops in deciduous forests E 3
Bog Turtle bogs, wet pastures, wet thickets T T(SIA) 2
Hellbender large and clear fast flowing streams SC FSC 1
Longtail Salamander moist woods, floodplains SC 2
pools, bogs, and other wetlands in hardwood
Four -toed Salamander forests SC 2
FISH
Little Tennessee River Rosyside (LT), flowing pools streams and rivers throughout,
Clinostomus funduloides Dace
prefers headwater streams
SC 1
Etheostoma inscriptum
Etheostoma vulneratum
(S), two to twelve inches of water over cobble,
Turquoise Darter gravel, or bedrock SC 1
(LT) (FB), fast flowing water over rocky
Wounded Darter substrates
SC 1
Hybopsis monacha
Luxilus chrysocephalus
Notropis lutipinnis
Percina squamata
(LT), formerly (FB)- rocky areas in small
Spotfin Chub streams
(C) (LT), flowing pools in medium sized creeks and
Striped Shiner streams
T T 0
T 0
(S) (LT) (B), pools over coarse substrates of
Yellowfin Shiner gravel and rock SC 1
(T)-fast flowing, deep, clear water over gravel,
Olive Darter cobble, and rocky substrates. SC FSC 1
FRESHWATER MOLLUSKS
(T), including (FB) (P) and (LT) riffles over
Alasmidonta raveneliana Appalachian Elktoe sand, gravel and cobble
Alasmidonta viridis Slippershell mussel
E E 0
(T) (FB), riffles over coarse to rocky substrates E 0
(LT) (H), up to three meters of water, no
Elliptio dilatata Spike preference of substrate SC 0
Fusconaia bamesiana Tennessee Pigtoe (LT) (H), sand/gravel riffles and shoals E 0
(T), including (FB) (P) and (LT) riffles over
Lampsilis fasciola Wavy -rayed lampmussel sand, gravel and cobble SC 0
(M), riffles of high -gradient headwater
Pegias fibula Littlewing Pearlymussel streams, prefers tributaries E E 0
Villosa iris Rainbow (LT) (H), headwater areas with sand and silt SC 0

Table 5. Protected Species from Macon County, NC - November 2001 3 of 4
Latin Name
TERRESTRIAL MOLLUSKS
Fumonelix orestes
Glyphyalinia junaluskana
Glyphyalinia pentadelphia
Haplotrema kendeighi
Inflectarius ferrissi
Pallifera hemphilll
Paravitrea umbilicaris
Paravitrea lamellidens
Patera Clarki
Zonitoides patuloides
Common Name
Engraved covert
Dark Glymph
Pink Glymph
Blue -foot Lancetooth
Smokey Mountain covert
Black Mantleslug
Open Supercoll
Lamellate Supercoll
Dwarf Proud Globe
Appalachian Gloss
HABITATS (Legrand and Hall, 1999)
high elevation rock crevaces, endemic to Piott
Balsams
mountainside deciduous forests leaflitter
mountainside deciduous forests leaflitter
mountainside deciduous forests leaflitter
2,500 to 6,600 feet, rotting logs, sphagnum,
fungi and seepage water
high elevation and sprucelflr forests (mainly
above 5,000 feet)
Status Likelihood in
State Federal Service Area
T
SC
SC
SC
• T
SC
moist deep leaflitter on hillsides and in ravines SC
moist deep leaflitter on hillsides and in ravines,
2-12 inches below talus SC
leaf litter of high -elevation mountainsides (up
to 6,500 feet) SC
moist deep leaflitter on hillsides and in ravines SC
0
2
2
2
2
0
2
2
0
2
LICHENS, MOSSES, AND LIVERWORTS
Bryocrumia vivicolor Gorge Moss
Cheilolejeunea evansii Liverwort
Gymnoderma lineare Rock Gnome Lichen
Plagiochila caduciloba Liverwort
Schlotheimia lancifolia Highland Moss
Sphenolobopsis pearsonii Liverwort
Tortula ammonsiana Ammon's tortula
rocks and streambanks in humid gorges,
waterfall spray zones
bark of hardwoods in humid gorges
above 5,000 feet or in deep gorges, rock
surfaces with high humidity
rocks and streambanks in humid gorges,
waterfall spray zones
Bark of hardwoods in cove forests
bark of frazier fir, in spruce/fir forests
areas where nutrient rich seepage covers
shaded rock surfaces
E FSC
E
T E
E
T
E FSC
2
2
2
2
3
0
E 2

Table 5. Protected Species from Macon County, NC - November 2001 4 of 4
Latin Name
PLANTS
Buckleya distichophylla
Carex radfordii
Delphinium exaltatum
Filipendulla rubra
Gentianopsis crinita
Grammitis nimbata
Helonias bullata
Hierochloe odorata
Hydrastis canadensis
Hymenophyllum tayloriae
Common Name
Piratebush
Radford's Sedge
Tall Larkspur
Queen -of -the -prairie
Fringed Gentian
West Indian Dwarf Polypody
Swamp Pink
Holy Grass
Goldenseal
Gorge Filmy Fem
HABITATS (Legrand and Ha11, 1999)
parasite of hemlocks, needs open canopy
rich cove forests and marble ravines
grassy balds, glades, open woodlands, usually
over mafic rock
moist lowland areas with open canopy, bogs,
marshes
moist meadows and hillside seeps
wet, mossy rock ledges
wetland areas with saturated (not flooded)
soils
moist meadows or swales
rich woodlands
moist grottoes and spray cliffs in escarpment
gorges with high rainfall
Status Likelihood in
State Federal Service Area
E FSC
E
E-SC FSC
E
E-SC
E-SC
T-SC T
E
E-SC
2
2
2
2
2
2
2
2
2
2
Isotria medeoloides
Lysimachia fraseri
Senecio m!!lefolium
Small Whorled Pogonia
Fraser's Loosestrife
Divided -leaf Ragwort
Spiraea virginiana
Sporobolus heterolepis
Trichomanes boschianum
Trichomanes petersii
open, dry woodlands, usually with acid soils
roadsides, forests, and alluvial meadows
on or near rock outcrops
requires periodic scouring floods, rocky
riverbanks in gorges or canyons
pine barrons over olivine
moist rocks and humid ravines, waterfall spray
zones
moist rocks and humid gorges
basic to circumneutral soils in rich coves and
Trillium discolor Mottled Trillium on forested slopes
(T)-Tennesssee, (M)-Mississippi Drainages: River Basin Abbeviations: (C)-Callasaja
(LT) -Little Tennessee, (FB)-French Broad, (H)-Hiwassee, (B)-Broad, (S)-Savannah, (C)-Cane
E= Endangered, T= Threatened, SC= Special Concem, FSC= Federal "Species of Concern"
O=Unlikely to occur in the service area or in the Cullasaja River Below Highlands.
1=Lilely to occur in lower Cullasaja River or Chattooga River Tributaries Downstream of the servie area.
2=May occur in Highlands service area, based on nearby records or presence of suitable habitat
3=Very likely in Highlands service area, based on recent records within the service area.
Virginia Spirea
Prairie Dropseed
Appalachian Filmy -fern
Dwarf Filmy -fern
E T
E FSC
T-SC FSC
2
2
2
E T
E
T
T
0
2
2
2
2

Table 6. Natural Heritage Program Registered Heritage Areas and Dedicated Nature Preserves within 1.5 Miles of the Highlands VV TP
Service Area - Macon County, NC - 2002
Name
Designation Ownership Management
Acres
CHATTOOGA RIVER GORGE/ELLICOTT ROCK RHA
RHA
FEDERAL
USDA -FOREST SERVICE
1997
CHATTOOGA RIVER GORGE/ELLICOTT ROCK RHA
RHA
FEDERAL
USDA -FOREST SERVICE
1997
COLE MOUNTAIN/SHORTOFF MOUNTAIN RHA
RHA
FEDERAL
USDA -FOREST SERVICE
56
CULLASAJA GORGE RHA
RHA
FEDERAL
USDA -FOREST SERVICE
1425
CULLASAJA GORGE RHA
RHA
FEDERAL
USDA -FOREST SERVICE
1425
HENRY M. WRIGHT PRESERVE DNP
DNP
PRIVATE
THE NATURE CONSERVANCY
22
KELSEY RHA
RHA
FEDERAL
USDA -FOREST SERVICE
256
OLIVE RHA
RHA
PRIVATE
NC BOTANICAL GARDEN
4
PINKY FALLS RHA
RHA
PRIVATE
NC BOTANICAL GARDEN
6
SATULAH MOUNTAIN SUMMIT RHA
RHA
PRIVATE
SATULAH SUMMIT-RAVENEL PARK, INC
54
SLICK ROCK RHA
RHA
FEDERAL
USDA -FOREST SERVICE
11
WHITESIDE MOUNTAIN RHA
RHA
FEDERAL
USDA -FOREST SERVICE
220

H
h ELF
S�
Pi 6
ER Wel
Ra W
D
ea]
102
0
V

Macon County, North Carolina
Service Area Boundary
Existing Town Limits
1O6North Annexation
1U6South Annexation
F!ot Mountain Annexation
�--�Highlands Falls Annexation
North Annexation
/\/Proposed Collection System
Figure 1. Town of Highlands VVVVTP
and Potential Annexation Area Locations
Macon County, NC
ENVIRONMENTAL CONSULTANTS
Rv|oinh.mG
,xww40xcamxoa.cnm

(C-Tr) \
WWTP Outfall
i
andall Lake
— ^ i
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Chatooga River tributaries
c'eek lc-")
Macon County, North Carolina
O
4,
•
0
0
0
Figure 3. DWQ Water Quality
Classifications of Streams and
Lakes Draining the Service and
Project Areas- Macon and
Jackson Counties, NC
Wa 'yam 8coLoariedeo,
ENVIRONMENTAL CONSULTANTS
Raleigh, nc
www.rjgaCarolina.com
Classification Boundary
J Service Area
0.5
0.5 Miles

1
OC
ob
10
•000
4n
Figure 4. Protected Water Supply Watersheds and WS-Critical Areas in
the Expanded Highlands Service Area, Macon County, N.C. DWQ
Supplementary Usage Classifications -Tr and -ORW are not shown.
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
v
•
39•
3-

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c
ln4
/1
l \ )
Figure 5.0. Wetland and Stream Impacts
Index - Town of Highlands Wastewater
System Expansion - Macon County, NC
ENVIRONMENTAL CONSULTANTS
Raleigh, NC
www.rjgaCarolina.com
LEGEND
Service Area Boundary
D Existing Town Limits
M 106 North Annexation
IM 106 South Annexation
E3 Flat Mountain Annexation
North Annexation
Al Environmentally Preferred Alignment
Jurisdictional Surface Waters
Wetlands
2000
0
2000 Feet
c\

•
•
,
•
I 181 w
•
Ns\c- e‘it,
LEGEND
Service Area Boundary
1=1 Existing Town Limits
106 North Annexation
106 South Annexation
ED Flat Mountain Annexation
North Annexation
NEnvironmentally Preferred Alignment
A/Jurisdictional Surface Waters
_ Wetlands
? Stream Crossings
500 0 500 Feet
•-•
•
, . ••.\,"
Figure 5.1. Wetland and Stream Impacts
Noth Annexation Area- Town of Highlands
Wastewater System Expansion -
Macon County, NC
MVIRONMENTAL CONSULTANTS
Raleigh, NC
www.rjgaCarolina.com

ii
•
f< toy
81, f 1411 w _
•
LEGEND N�
Service Area Boundary
® Existing Town Limits
® 106 North Annexation
® 106 South Annexation
® Flat Mountain Annexation
North Annexation
Environmentally Preferred Alignment
A/Jurisdictional Surface Waters
Wetlands
? _ Stream Crossings
[? L Impacted Wetlands
500 0 500 Feet
Figure 5.2. Wetland and Stream Impacts
Flat Mountain Annexation and US 64
- Town of Highlands Wastewater System
Expansion - Macon County, NC
ENVIRONMENTAL CONSULTANTS
Raleigh, NC
www.rjgaCarolina.com
w.ip

1, _h ; 4.ry. ram ,- •—, •,. .
r�� �'",-. 1.' i Alt
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LEGEND
Service Area Boundary
® Existing Town Limits
® 106 North Annexation
® 106 South Annexation
® Flat Mountain Annexation
North Annexation
"Environmentally Preferred Alignment
Jurisdictional Surface Waters
Wetlands
Stream Crossings
? Impacted Wetlands
500 0
ti
tl
500 Feet
Figure 5.3. Wetland and Stream Impacts
Hwy. 106 North and South Annexation Are,
Town of Highlands Wastewater System
Expansion - Macon County, NC
ri f �ala�afer�v 91-'..eilaaoektlev
ENVIRONMENTAL CONSULTANTS
Raleigh, NC
www.rjgaCarolina.com
rKv.� •y 1
t l .
yam. — ,

APPENDIX A. Protected Species Descriptions, Habitat Requirements,
and Likelihood of Occurrence in the Highlands Project Area.
The proposed VWVfP construction area was cleared and graded in 1994, and does not
provide suitable habitat for any of the 71 state or federal protected species known to occur in
Macon or Jackson counties. None of these species was observed during the field survey and
none is likely to occur on the site, other than as an occasional transient. However, the existing
and future Highlands wastewater service area contains suitable habitat for many of these
species, as documented below and summarized in Table 5.
A.1. Rafinesque's Big -eared Bat (Corynorhinus rafinesquii).
North Carolina Special Concem, Federal Species of Concern.
This bat has large ears that are curled when at rest, and fleshy knobs between the nostrils
and eyes. The fur is longer than on the similar P. townsendii, and the hairs are black at the base
and yellow to white at the tips. It roosts in dilapidated buildings near permanent water, and forages
over the water surface at night. It is apparently non -migratory, and hibemates in winter. NHP has
one historic element occurrence record of this bat from 1948 inside the Town limits. It probably
occurs as an occasional transient in the Highlands area, as no regular roosting sites have been
found in this area.
A.2. Northern Long-eared Bat (Myotis septentrionalis).
North Carolina Special Concem.
This bat is dull brown above and paler below. The long ears, which extend past the muzzle
when pointed forward, and the long pointed tragus distinguish this species from other Myotis
species (Webster et al., 1985). It inhabits the westem mountain counties of North Carolina (Lee et
al., 1982) where it roosts singly or in small matemity groups near caves or mines, but never in large
colonies and seldom in buildings. This species typically swarms around cave entrances in late
summer. NHP has a 1965 record of the long-eared bat inside the Town limits near Ravenel Lake. It
probably occurs as an occasional transient in the Highlands area, as no regular roosting sites have
been found in this area.
A.3. Indiana Bat (Myotis sodalis).
North Carolina Endangered, Federal Endangered.
This bat is medium-sized and resembles the little brown bat (Myotis lucifugus). Although
its belly is pink, its fur is dull gray -brown. Basal portions of the hair on its dorsum are lead
colored. M. sodalis feeds on insects along forested stream corridors; riparian areas without trees
are generally not used (LaVal et al, 1976, 1977). Buildings and loose bark provide summer
roosting sites, while limestone caves are used during winter. NHP has no element occurrence
record of the Indiana bat within two miles of the Highlands area, but individuals may occur
sporadically in and around Highlands, based on sightings elsewhere in Macon and Jackson
counties.

A.4. Carolina Northern Flying Squirrel (Glaucomys sabrinus coloratus).
North Carolina Endangered, Federal Endangered.
The Carolina northern flying squirrel is 10 to 12 inches long. Adults are gray with a brown,
tan, or ruddy patch dorsally, and gray to white to white ventrally. Juveniles have a dark gray
dorsum and off-white undersides. This squirrel feeds on lichens, fungi, seeds, fruit, and buds in
mature forests (Weigl, 1968; Maser et. al., 1985; McKeever, 1960). It lives in transition zones
between coniferous and northern hardwood forests, usually above 5000 feet elevation. Both
forest types provide food sources, but hardwood areas are used for nesting. NHP has no
element occurrence record within 1.5 miles of the Highlands VWVfP or wastewater service area,
most of which is too low in elevation.
A.S. Eastern Woodrat (Neotoma floridana haematoreia).
North Carolina Special Concem, Federal Species of Concern.
This gray -brown rodent has a compact body and black -tipped hairs. The tail is dark dorsally
and nearly white ventrally. Colonies construct elaborate nests of twigs, leaves, and trash in
crevices or caves among rock outcrops in deciduous forests, and commonly aggregate shiny
objects in and around the nest site. NHP has two extant element occurrence records of the
eastem woodrat close to the proposed service area. No date is given for an occurrence near Little
Foderstack Mountain southeast of town. Another woodrat site was found in 1990 near Granite City
along the Macon/Jackson County line. Based on these recent records, other unknown populations
may occur in the Highlands service area.
A.6. Southern Rock Vole (Microtus Chrotorrhinus carolinensis).
North Carolina Special Concem, Federal Species of Concern.
The rock vole is similar to the meadow vole (M. pennsylvanicus) but has darker fur and a
yellow to orange snout. The southern population is disjunct from northern populations that occur
from northeast Pennsylvania to Canada. It prefers rocky areas in forests or fields, where it
burrows under logs, moss, and leaf litter (Webster et al, 1985). NHP has one recent record of
the southern rock vole inside the Town limits from 1990 on the lower slopes of Satulah Mountain
above Pierson Drive.
A.7. Long-tailed Shrew (Sorex dispar).
North Carolina Special Concem.
The long-tailed shrew occurs in deep rock crevices in cool, moist forests and along
mountain streams. Its fur is slate gray dorsally, and lighter ventrally. Long-tailed shrews have
thick tails 80 percent as long as the head and body length. Their average length including the tail
is 4.5 to 5.5 inches. NHP has a February 1992 record of this shrew from Cullasaja Gorge
northwest of the Highlands WWTP. Other unknown populations may occur along forested stream
corridors in the Highlands service area.
A.B. Southern Water Shrew (Sorex palustris punctulatus).
North Carolina Special Concem, Federal Species of Concern.

This shrew is dark gray to black dorsally and on the upper tail, and lighter on its belly and
underside of the tail. It is the largest Sorex in North Carolina, readily distinguished by its large,
densely haired feet and toes. It prefers streams bounded by beech, maple, rhododendron, and
birch, and mountain bogs dominated by willow, spruce, and hemlock (Webster et al., 1985). NHP
has a 1995 record of the southern water shrew along East Fork Overflow Creek southwest of
Highlands. Other unknown populations may occur along forested stream corridors in the
Highlands service area.
A.9. Southern Pygmy Shrew (Sorex hoyi winnemana).
North Carolina Special Concem.
This shrew has ruddy to brown fur in summer and gray to brown fur in winter. The body and
tail are darker above than below. The southem pygmy shrew is the smallest mammal in North
America (Webster et al, 1985). It inhabits well -drained ridges and slopes in hardwood forests, but
has also been collected in clear-cut areas. It frequents rotting Togs, stumps, and leaf litter, and is
seldom found near permanent water (Clark, 1987). NHP has no element occurrence records of
the southem pygmy shrew within two miles of Highlands, but the future service area contains
suitable habitat that may support unknown populations of this shrew.
A.10. Southern Appalachian Saw -whet Owl (Aegolius acadicus).
North Carolina Special Concem, Federal Species of Concern.
The southern Appalachian saw -whet owl frequents the spruce-fir/hardwood forest
transition zone. It nests in abandoned woodpecker holes 14 to 60 feet above ground. It is
distinguished from the screech owl (Otus asio) by its smaller size and lack of ear tufts. NHP has
recent records of this bird on the Highlands USGS quadrangle, but no record within 1.5 miles of
the Highlands VWVTP or service area, most of which is too low in elevation for spruce -fir forests.
A few of the higher ridges with mature forests in the future service area may provide suitable
habiatat for this owl.
A.11. Cooper's Hawk (Accipiter cooperii).
North Carolina Special Concem.
Cooper's hawk is larger than the more common sharp -shinned hawk (Accipiter striatus), and
has a proportionately larger head and wider, more rounded tail. Both species are blue -gray above
with rusty bars below as adults, and dark brown above with brown streaks below as juveniles
(Potter et al., 1980). Cooper's hawk requires large tracts of contiguous forest, either uplands or
floodplains, although it commonly forages in fields at the edge of forests. It is a winter resident in
the eastem two-thirds of North Carolina and migrates to the mountains or to northern latitudes
during spring to breed (Potter et al., 1980). NHP has no element occurrence record within 1.5
miles of the Highlands VWVfP or service area, but suitable habitat exists in much of the
undeveloped portions of the future service area.
A.12. Peregrine Falcon (Falco peregrinus).
North Carolina Endangered.

The peregrine falcon is a medium-sized raptor with long, pointed wings and a long tail.
The adult's slate gray body is black -barred on the wing, tail feathers, and flanks, the throat is
white and the sides of the head bear black markings resembling a moustache. The lower body is
white and ruddy, and spotted and barred with black. The falcon preys on bluejays, flickers,
meadowlarks, pigeons, starlings, shorebirds, waterfowl, and other birds. It hunts over open
waterways, fields, and wetlands. Preferred nesting sites are fissures in cliffs, but buildings are
also used. NHP has a recent nesting record of peregrine falcon on Whiteside Mountain within 1.5
miles of the Highlands service area. The numerous lakes in Highlands offer good foraging areas
for this falcon, and other suitable nesting sites may exist in the service area.
A.13. Bachman's Sparrow (Aimophila aestivalis).
North Carolina Special Concem, Federal Species of Concern.
Bachman's sparrow resembles the field sparrow (Spizella pusilla), which shares its habitat,
but is grayer and lacks a white eye -ring (Potter et al., 1980; Robbins et al., 1966). It is secretive
and usually seen only when males are singing during April and May. It nests in grassy undergrowth
of open pine woods, savannahs, and abandoned fields with scattered tall trees, especially in areas
recently burned. NHP has no records within 1.5 miles of the Highlands WWTP or service area.
Suitable habitat may exist within the service area.
A.14. Olive -sided Flycatcher (Contopus cooperi).
North Carolina Special Concem, Federal Species of Concern.
This flycatcher inhabits hemlock and spruce -fir forests in the mountains of western North
Carolina. It is a transient across the Piedmont and Coastal Plain during May, and from August
through October. It is stocky with a heavy bill, and is an insectivore. It nests on a branch seven to
100 feet above the ground, usually close to the trunk (Potter et al., 1980). NHP has one historic
nesting record from inside the Town limits, but that site was subsequently cleared for
development. Suitable habitat may exist within the service area.
A.15. Southern Appalachian Black -capped Chickadee (Poecile atricapilla practica).
North Carolina Special Concem, Federal Species of Concern.
Black -capped chickadees have whiter cheeks, slightly larger bodies, and rustier sides
than common Carolina chickadees. They breed above 4,000 feet in spruce -fir forests, and over -
winter at lower elevations, where they mingle with Carolina chickadees. Nesting cavities are
excavated in the trunks of dead trees, five to 60 feet above ground. Cavities are constructed by
pairs from April to early May. NHP has no nesting records within 1.5 miles of the Highlands
VWVfP or service area, but suitable habitat may exist on some high elevation forested ridges
within the future service area. Non -breeding black -capped chickadees likely occur in town,
especially at bird feeders during winter.
A.16. Appalachian Bewick's Wren (Thryomanes bewickii altus).
North Carolina Endangered, Federal Species of Concern.
Once plentiful, the decline of the Appalachian Bewick's wren coincides with the
introduction of the European starling and the house sparrow in the early 1900s. This wren occurs

in high elevation rural areas, often nesting in abandoned buildings or junked automobiles. It is
brown above, white below, and has a white eye -line. The long, rounded tail is frequently jerked
sideways. Males build several nests from February to May, and one is selected by the female.
The male then spends much time perching on the unused nests which serve as decoys to fool the
brown -headed cowbird (Molothrus ater), a nest parasite. NHP has three historic records inside
the Town limits, but all three sites have been destroyed. Although NHP has no recent records of
this wren near Highlands, suitable habitat may exist in rural portions of the future service area.
A.17. Bog Turtle (Clemmys muhlenbergii).
North Carolina Threatened, Federal Threatened by Similarity of Appearance.
The bog turtle has a plain brown carapace up to four inches long and a prominent yellow or
orange blotch on each side of the head and neck. It lives in rivulets and vegetated shallows in
bogs, marshes, wet meadows, and other upland depression wetlands with open canopy and a soft,
muddy substratum (Martof et al, 1980). Frequently scoured floodplains are not suitable, but seeps
or bogs along flood plain edges with minor scouring may be suitable. The bog turtle is usually
buried beneath vegetation or in mud, and rarely encountered except during the spring mating
season (Palmer and Braswell 1995). NHP has records of two potential bog turtle sites within one
mile outside the Highlands service area, one above Randall Lake in 1992 and the other along
Edwards Creek in 1980. It is unknown whether bog turtles presently exist at these sites, as it often
requires repeated surveys before a bog turtle is detected. Other suitable sites may exist in the
service area.
A.18. Mole Salamander (Ambystoma talpoideum).
North Carolina Special Concem.
This stocky, gray -brown salamander lives in burrows under logs and boulders in forests,
and breeds during winter and early spring in fish -free vemal pools (Martof et al., 1980). The
breeding pools may be flood plain depressions, upland depressions, Carolina bays, sinkhole ponds,
bogs, or seeps. The larvae feed on aquatic invertebrates. NHP has no record of the mole
salamander within several miles of the Highlands VWVTP or service area. Suitable habitat may exist
within the service area.
A.19. Longtail Salamander (Eurycea longicauda longicauda).
North Carolina Special Concem.
This salamander is four to eight inches long including a tail that comprises two-thirds of its
length. It is yellow to orange -red with black spots on the sides and back. It prefers damp caves,
seeps, and small rocky streams with shale and limestone in the Little Tennessee River basin
(Martof, et al., 1980). Eggs are attached to rocks or logs just above the waterline in cavities or
burrows along the banks of small streams. They hatch in winter and the larvae are aquatic. NHP
has no record of the Iongtail salamander within several miles of the Highlands VWVI'P or service
area, but suitable habitat may exist within the service area.
A.20. Four -toed Salamander (Hemidactylium scutatum).
North Carolina Special Concem.

This small, slender salamander has a ruddy brown dorsum and a white belly with
conspicuous black spots. It has four toes on each hind foot, and a constriction at the base of the
tail (Hall, 1991). Adults are terrestrial, but rarely encountered except when breeding. Eggs are laid
in late winter or early spring beneath clumps of moss on logs or rocks at the edge of fish -free vemal
pools, bogs, or seeps. NHP has no record of the four -toed salamander on the Highlands USGS
quadrangle, but suitable habitat may exist within the service area.
A.21. Green Salamander (Aneides aeneus).
North Carolina Endangered.
This salamander lives in moist crevices of rock outcrops in hardwood forests. It has green
to yellow -green patches on a dark brown to gray dorsum. Eggs are laid in late spring to early
summer, and attended by females during the three month development period. Newly hatched
young are 20 mm long, terrestrial, and similar to adults. NHP has numerous historic and recent
records of the green salamander in and around the Highlands area, including sites near Bowry
Road, Sassafras Knob, Highlands Falls, Satulah Falls, Blue Valley, Granite City, Little
Fodderstack Mountain, and Brooks Creek. None of these sites is close to the VW TP property,
which does not contain suitable habitat. Other unknown populations may also occur in the
Highlands service area.
A.22. Hel!bender (Cryptobranchus alleganiensis).
North Carolina Special Concern, Federal Species of Concern.
This large salamander occurs in clear, high gradient rivers with large flat rocks, and feeds
on insects and crayfish. It reaches 12 to 29 inches in length, and newly hatched individuals are
30 mm long. It is brown to gray with dark spots. Eggs are laid in summer under flat rocks in
current, and attended by the male until hatching. At 18 months of age the larvae lose their
extemal gills and become juveniles. NHP has no record of the hellbender on the Highlands
USGS quadrangle, but has recent and historic records from the lower Cullasaja River between
Cullasaja Gorge and Town of Franklin. Streams in the Highlands service are too small to provide
suitable habitat. Impacts to water quality and hydrology of the Cullasaja River may affect this
salamander.
A.23. Little Tennessee Rosyside Dace (Clinostomus funduloides ssp).
North Carolina Special Concem.
The Lithe Tennessee rosyside dace, also known as smoky dace, is endemic to upland
drainages in the Little Tennessee River. It feeds primarily on drifting insects (Menhinick and
Braswell, 1997). The body is olive with a diffuse dark band along the side and red behind the gill
cover (Rohde et al., 1994). In breeding males the red pigment extends the entire side, with a
gold line stripe above the red area. It is most common in flowing pools of rocky headwater
streams, and rare in large streams. NHP has no record of this fish on the Highlands USGS
quadrangle, but recent records exist from the Cullasaja River and several tributaries downstream
of Highlands, below Dry Falls. Streams in the Highlands service area may contain suitable habitat
for this dace, but Dry Falls and Sequoyah Dam prevent its colonization of the upper Cullasaja
River.

A.24. Spotfin Chub (Cyprinella monacha).
North Carolina Threatened, Federal Threatened.
The spotfin chub, also known as turquoise shiner, has a silvery -blue laterally compressed
body with small scales, a faint lateral stripe extending to a prominent black caudal spot, and a
long snout with subterminal mouth and maxillary barbels (Rohde et al., 1994; Menhinick and
Braswell, 1997). Breeding males develop turquoise sides with two broad white vertical bars and
turquoise fins with white edges. It occurs in rocky areas in clear, medium to large streams, and
spawns in rocky crevices in moderate current. The only extant population known in North
Carolina is in the Little Tennessee River between Lake Emory dam and the backwaters of
Fontana Lake. It is apparently extirpated from other locales in its historic range, which might
have included the lower Cullasaja River near Franklin (Menhinick and Braswell, 1997; WRC
website 2001). NHP has no record of this minnow in the Cullasaja River watershed or on the
Highlands USGS quadrangle.
A.25. Striped Shiner (Luxilus chrysocephalus).
North Carolina Threatened.
The striped shiner is a deep, laterally compressed minnow with four dark longitudinal
stripes along the back (Rohde et al, 1994; Menhinick and Braswell, 1997). It prefers flowing
pools in medium to large streams, feeds on drifting insects, and spawns primarily on nests of the
river chub (Nocomis micropogon). The striped shiner has recently been collected in the Little
Tennessee River in northern Macon County, but NHP has no records from the Cullasaja River
watershed or elsewhere upstream of Lake Emory, where it might have occurred historically.
A.26. Wounded Darter (Etheostoma vulneratum).
North Carolina Special Concem.
The wounded darter is olive with red spots and narrow horizontal lines on the sides, and
dark margins in the second dorsal, caudal, and anal fins (Rohde et al., 1994; Menhinick and
Braswell, 1997). It feeds on benthic invertebrates and spawns on the undersides of large rocks in
moderate to swift current in rocky riffles in the Little Tennessee River and major tributaries that
include the lower Cullasaja River below Cullasaja Gorge (NHP database and William McLamey
field records). NHP has no record of this fish above the gorge or on the Highlands USGS
quadrangle.
A.27. Olive Darter (Percina squamata).
North Carolina Special Concem, Federal Species of Concern.
The olive darter is green to gray with a row of dark blotches along the side, an orange
submarginal band in the spiny dorsal fin, small scales, and an elongate head (Rohde et al, 1994;
Menhinick and Braswell, 1997). It feeds on benthic invertebrates and spawns on gravel shoals in
moderate to swift current. It occurs in deeper riffles and high gradient runs with cobble and
boulders in the Little Tennessee River and its major tributaries, including the lower Cullasaja
River below Cullasaja Gorge (NHP database and William McLarney records). NHP has no record
of this fish above the gorge or on the Highlands USGS quadrangle.

A.28. Turquoise Darter (Etheostoma inscriptum).
North Carolina Special Concem.
The turquoise darter has six dark blotches on its back and on each side. The scales on its
flanks have red centers forming horizontal rows of dots (Rohde et al., 1994; Menhinick and
Braswell, 1997). The face, cheek, and breast become turquoise during breeding, especially in
males. This darter occurs in riffles two to 12 inches deep in small streams with gravel, cobble,
and bedrock substrata, and feeds on benthic invertebrates. It is endemic to the Savannah River
basin, including some Chattooga River tributaries that drain southem and eastern Highlands
(NHP database). NHP has no record of this fish within one mile of the service area, but perennial
streams in southem and eastem Highlands may be suitable and may support unknown
populations. It does not occur in the Cullasaja River or elsewhere in the Tennessee River basin.
A.29. Yellowfin Shiner (Notropis lutipinnis).
North Carolina Special Concem
The yellowfin shiner is reddish -brown dorsally with a broad dark stripe down the side and
reddish fins. The head and fins of breeding males turn yellow to orange. This minnow occurs in
runs and pools in small streams with gravel, cobble, and bedrock substrata, where it feeds on
benthic and drifting invertebrates, and spawns on chub nests (Nocomis spp.). In Macon County
the yellowfin shiner is limited to the Savannah River basin, including Chattooga River tributaries,
which drain southem, and eastem Highlands (NHP database). NHP has no record of the yellowfin
shiner within one mile of the service area, but perennial streams in southern and eastern
Highlands may be suitable and may support unknown populations. It does not occur in the
Cullasaja River watershed and is not native in the Tennessee River basin.
A.30. River Mussels (Seven Species).
Seven species of river mussels are known from the Little Tennessee River downstream of
Lake Emory in Macon County. They are the slippershell mussel (Alasmidonta viridis - North
Carolina endangered), Appalachian elktoe (Alasmidonta ravenellana — North Carolina and
Federal endangered), spike (Elliptio dilatata - North Carolina special concem), Tennessee pigtoe
(Fusconaia bamesiana - North Carolina endangered), wavy -rayed lampmussel (Lampsilis fasciola
- North Carolina special concem), littlewing pearlymussel (Pegias fabula — North Carolina and
Federal endangered), and rainbow mussel (Villosa iris - North Carolina special concern).
The rainbow mussel occurs in backwaters with fine sand and silt, or under large rocks in
faster flows. The littlewing pearlymussel lives in riffles in high -gradient small streams. The five
other species occur in runs and shoals of medium to large streams with moderate to fast current
with substrata of coarse sand, gravel, and cobble (Adams et al. 1990). Some of these mussels
may have historically occurred in the Cullasaja River and tributaries, but no mussel surveys were
conducted until long after deforestation, agriculture, dams, and development changed the habitat.
No current or recently extirpated populations are known upstream of Lake Emory. None of these
species is reported from the Cullasaja River watershed or on the Highlands USGS quadrangle
(NHP and WRC databases) despite mussel surveys by WRC and other agencies during the past
20 years. Consequently, none is likely to be affected by this project.
The biological nutrient removal and non -chlorine disinfection to be installed in the
expanded WWTP should provide improved effluent quality that may benefit mussel habitat

downstream of Lake Sequoyah Dam and may allow future recolonization (by human
translocation) to the lower Cullasaja River. WRC and others are developing techniques to
propagate and move protected mussels in order to re-establish lost populations. Successful
recolonization will also depend on riparian corridor protection.
A.31. Terrestrial Mollusks (Ten Species).
The Plott Balsam Mountains 20 miles north of Highlands are home to two endemic
terrestrial snails. The engraved covert (Fumonelix orestes - North Carolina threatened) lives at
high elevations in rock crevices, venturing out during wet weather. The Smokey Mountain covert
(Inflectarius fern►ssi - North Carolina threatened), endemic to both the Plott Balsam and Great
Smokey mountain ranges, occurs between 2,500 and 6,600 feet near rotting logs, sphagnum
moss, fungi and seepage water (Adams et al. 1990).
The dark glyph (Glyphyalinia junaluskana - North Carolina special concem), pink glyph
(Glyphyalinia pentadelphia - North Carolina special concem), and blue -foot lancetooth
(Haplotrema kendeighi - North Carolina special concem) occur in leaf litter on mountainside
upland and deciduous forests, and venture into the open during wet weather.
The open supercoil (Parabitrea umbilicaris - North Carolina special concern), Appalachian
gloss (Zonitoides patuloides - North Carolina special concern), and lamellate supercoil
(Paravitrea lamellidens - North Carolina special concem) occur in deep moist leaf litter on
hillsides and in ravines. Lamellate supercoil has also been found on high elevation slopes, two to
12 inches below the talus on mossy patches that were supporting herbaceous vegetation.
The dwarf proud globe (Patera clarki - North Carolina special concern) occurs in leaf litter
at middle and high elevation mountain sides up to 6,500 feet. Black mantleslug (Pallifera
hemphilli - North Carolina special concern) is known mainly from spruce -fir forests above 5,000
feet, and is active during wet weather (The Scientific Council on Freshwater and Terrestrial
Mollusks, 1990).
NHP has no record of these ten terrestrial snails within 1.5 miles of the project service
area or elsewhere on the Highlands USGS quadrangle. Suitable habitat may exist in the
proposed service area for some of these species that occur on moist wooded slopes and are not
limited to elevations above 4,500 feet. Terrestrial snail distributions are poorly known (compared
with other rare species groups) and many undetected populations may exist, especially in
southwestern NC.
A.32. Rock Gnome Lichen (Gymnoderma lineare).
North Carolina Threatened, Federal Endangered.
This member of the reindeer moss family is the only member of its genus in North
America. It reproduces asexually and forms dense, colonial colonies on rock surfaces with high
humidity. Rock gnome lichen is blue -grey on the upper surface, white below, and black basally.
The apothecia are borne singly or in clusters, and terminally on the tips of the squamules, and
have been found from July through September. Rock gnome lichen is endemic to the southem
Appalachian mountains of North Carolina and Tennessee, where 32 populations remain. Only
seven of the remaining populations cover an area larger than two square meters, and most are
above 5,000 feet, where frequent fog provides moisture, and on vertical rock faces. They also

grow deep in gorges at lower elevations. NHP has a 1996 record of this lichen on the southwest
slope of Whiteside Mountain, one mile northeast of the proposed service area. Other unknown
populations may exist in the service area, although suitable habitat is limited.
A.33. Liverworts (Three Species).
Three protected liverworts are known from Macon and Jackson counties. Cheilolejeunea
evansii (North Carolina proposed endangered) occurs on the bark of hardwoods in humid gorges
and Plagiochila caduciloba (North Carolina endangered) occurs on rocks and stream banks in
humid gorges and in the spray zone of waterfalls. Sphenolobopsis pearsonii (North Carolina
proposed endangered and Federal species of concern) grows on Frazier fir bark in high -elevation
spruce -fir forests (Amoroso, 1999). NHP has two P. caduciloba records within 1.5 miles of the
service area, at Dry Falls in 1978 and at Glen Falls in 1961. NHP had no records for the other
two liverworts within 1.5 miles of the service area or elsewhere on the Highlands USGS
quadrangle. Unknown populations of these liverworts may exist along forested stream corridors
in the service area.
A.34. Mosses (Three Species).
Three protected moss species are known from Jackson and Macon counties. Gorge
moss (Bryocrumia vivicolor- North Carolina endangered and Federal species of concern) occurs
on rocks and stream banks in humid gorges and in the spray zone of waterfalls, and Highland
moss (Schlotheimia lancifolia - North Carolina threatened) occurs the bark of hardwoods in cove
forests. Ammon's tortula (Tortula ammonsiana - North Carolina endangered) occurs where
nutrient rich seepage covers shaded rock faces. NHP has three 1997 records of Highland moss
within Town limits and within the Highlands Falls annexation area. NHP has no records for gorge
moss or Ammon's tortula within 1.5 miles of the service area. Unknown populations of these
mosses may exist along forested stream corridors in the service area.
A.35. Filmy -ferns (Three Species).
The Appalachian filmy-fem (Trichomanes boschianum - North Carolina threatened) occurs
in the spray zone of waterfalls and in rocky seeps (Amoroso, 1999). Dwarf filmy-fem
(Trichomanes petersii - North Carolina threatened) occurs on moist rocks in humid gorges.
Gorge filmy fern (Hymenophyllum tayloriae - North Carolina proposed endangered) inhabits moist
grottos and spray cliffs in escarpment gorges with high rainfall (Amoroso, 1999). NHP has one
record of Appalachian filmy-fem within 1.5 miles of the service area at Dry Falls in 1949, but the
site has been destroyed. NHP has no record of dwarf filmy-fem within 1.5 miles of the service
area, but recent records do exist on the Highlands USGS quadrangle. NHP has one record of
gorge filmy-fem within 1.5 miles of the service area in 1998 near Brooks Creek. Other unknown
populations of these ferns may exist along forested stream corridors in the service area.
A.36. West Indian Dwarf Polypody (Grammitis nimbata).
North Carolina Endangered, Federal Species of Concern.

Macon County has the only known continental population of this West Indian fem. It is a
perennial that grows from tiny rhizomes on wet, mossy rock ledges. Its tiny leaflets are covered
with dark brown bristles (Radford et al, 1968). NHP has one record within 1.5 miles of the
service area during 1989 at Dry Falls. Other unknown populations of this fern may exist along
forested stream corridors in the service area.
A.37. Piratebush (Buckleya distichophylla).
North Carolina Endangered, Federal Species of Concern.
Piratebush is a small, dioecious, parasitic shrub attached to hemlock roots that blooms
from April to May. Because hemlock is a shade tolerant and densely foliated tree, and piratebush
requires open sunlight, the parasite is typically encountered only in openings of hemlock stands
on open cliffs or bluffs (Radford et al., 1968). NHP has no records of piratebush within 1.5 miles
of the service area or elsewhere on the Highlands USGS quadrangle. Hemlock forest is common
in Highlands, and unknown populations of piratebush may occur in the service area.
A.38. Queen of the Prairie (Filipendulla rubra).
North Carolina Endangered.
The five -petaled, pink flowers of this perennial herb appear from June to July and are
borne in a flat-topped panicle. It grows in moist lowland areas with an open canopy and in bogs
(Radford et al., 1968). NHP has no records of queen of the prairie within 1.5 miles of the service
area or elsewhere on the Highlands USGS quadrangle. Unknown populations may occur in wet
meadows or seeps in the Highlands service area.
A.39. Fringed Gentian (Gentianopsis crinita).
North Carolina Endangered and Special Concern.
Fringed gentian is an annual herb bearing blue to purple and occasionally white flowers
from September to October. It grows in moist meadows and near hillside seeps (Radford et al.,
1968). NHP has no records of fringed gentian within 1.5 miles of the service area or elsewhere
on the Highlands USGS quadrangle. Unknown populations may occur in wet meadows or seeps
in the Highlands service area.
A.40. Holy Grass (Hierochloe odorata).
North Carolina Endangered.
The brown, bronze or purple flowers of this prairie disjunct appear in April. Plants arise
from the previous year's growth in moist meadows or swales (Femald, 1950). NHP has no
records of holy grass within 1.5 miles of the service area or elsewhere on the Highlands USGS
quadrangle. Unknown populations may occur in wet meadows in the Highlands service area.
A.41. Virginia Spirea (Spiraea virginiana)
North Carolina Endangered, Federal Threatened.

During June and July, Virginia spirea bears cream colored flowers on branched and flat-
topped axes. Up to 10 feet tall, the arching, upright stems are alternately leaved. Leaves are
polymorphic. The plant reproduces clonally, forming dense clumps in rock crevices and around
boulders. Virginia spirea is a primary successional species that inhabits rocky river banks in
gorges and canyons and requires periodic scouring floods to control competition by taller woody
plants. NHP has no record of Virginia spirea within 1.5 miles of the service area or elsewhere on
the Highlands USGS quadrangle. No suitable habitat exists in the Highlands service area.
A.42. Radford's Sedge (Carex radfordii).
North Carolina Proposed Endangered.
Radford's sedge occurs on calcareous, often rocky, well -drained soils of mesic cove
forests and woodlands. Most of the few known sites are located in a belt of high pH soils with high
concentrations of calcium and magnesium. A robust perennial sedge, the stems are 4-6
decimeters (dm) tall (usually 1.5 times longer than the leaves). It blooms in May and June and is
distinguished from other Carex species by its long awns, blue-green leaf blades, and brown to
white basal sheaths (Nature Serve, 2002). NHP has no records of Radford's sedge within 1.5
miles of the service area or elsewhere on the Highlands USGS quadrangle. Unknown populations
may occur in the Highlands service area.
A.43. Tall Larkspur (Delphinium exaltatum).
North Carolina Endangered and Special Concern, Federal Species of Concern.
This distinctive perennial wildflower of the buttercup family has altemate, palmately -cleft
leaves, a smooth stem, a hard rootstock, and grows up to two meters tall. The flowers are
produced from July to September and have spurred sepals and petals. It grows on grassy balds,
glades, and in open woodlands, usually over mafic rock. NHP has no records of tall larkspur within
1.5 miles of the service area or elsewhere on the Highlands USGS quadrangle. Unknown
populations may occur in the Highlands service area.
A.44. Swamp Pink (Helonias bullata).
North Carolina Threatened and Special Concern, Federal Threatened.
Swamp pink's 30 to 50 pink flowers bloom from March to May on racemous scapes. Its
leaves are evergreen, lance -shaped, parallel -veined, and form basal rosettes. This lily is usually
20 to 90 centimeters tall during flowering, and up to 1.5 meters during seed maturation.
Reproduction is usually asexual and dense colonial root sprouts are common. Swamp pink is
shade tolerant and occurs in a variety of wetland habitats. It requires saturated but not flooded
soils and is commonly associated with evergreen trees. NHP has no records within 1.5 miles of
the service area or elsewhere on the Highlands USGS quadrangle. Unknown populations may
occur in wetlands in the Highlands service area.
A.45. Goldenseal (Hydrastis canadensis).
North Carolina Endangered and Special Concern.

Goldenseal's single yellow flower is bome between two terminal leaves in April. A third
leaf is present at the base of a stem that arises from a knotty, yellow rhizome collected for folk
medicine use. The one- or two -seed crimson fruits are borne from May to June. Goldenseal
thrives in rich woodlands. NHP has no records within 1.5 miles of the service area or elsewhere
on the Highlands USGS quadrangle. Unknown populations may occur in the Highlands service
area.
A.46. Small Whorled Pogonia (Isotria medeoloides).
North Carolina Endangered, Federal Threatened.
Small whorled pogonia's one or two yellow -green flowers appear between mid -May and
mid -June, and only persist a few days. The flowers are borne terminally on the stem, and
produce several thousand tiny seeds. Small -whorled pogonia grows in open, dry to mesic,
deciduous woods with acidic soil. Dense surrounding scrub inhibits flowering, and some
populations may remain dormant for a few years before sprouting and blooming. NHP has no
records within 1.5 miles of the service area or elsewhere on the Highlands USGS quadrangle.
Unknown populations may occur in the Highlands service area.
A.47. Fraser's Loosestrife (Lysimachia fraseri).
North Carolina Endangered, Federal Species of Concern.
The purple -margined flowers of Fraser's loosestrife appear in June on leafy panicles. The
lanceolate, glandular leaves are born in whorls of three to five on the stem. Fraser's loosestrife
grows along moist roadsides and in alluvial meadows in the southwest mountains of North
Carolina (Amoroso, 1999; Radford et al., 1968). NHP has records of three extant, .one historic,
and one destroyed population within 1.5 miles of the service area. The plant was observed
above Whiteside Cove during June 1993 and above Horse Cove and near Granite City during
June 1997. Other unknown populations of this plant may exist in open -canopy moist to wet areas
in the service area.
A.48. Divided -leaf Ragwort (Senecio millefolium).
North Carolina Threatened, Federal Species of Concern.
The numerous yellow disk flowers of divided -leaf ragwort appear from late April through
early June. The leaves are mostly basal and finely bipinnately to tripinnately dissected. It grows
on or near rock outcrops (Radford et al., 1968). NHP has no records within 1.5 miles of the
service area or elsewhere on the Highlands USGS quadrangle. Unknown populations may occur
in the Highlands service area.
A.49. Prairie Dropseed (Sporobolus heterolepis).
North Carolina Endangered.
Prairie dropseed is a cespitose perennial that grows in pine barrens over olivine rock
(Amoroso, 1999). These are mafic silicates high in magnesium and iron with basic pH. The
leaves are basal, chlorotic green, and with cobweb -like hairs in the throat. Flowers appear from
August to September. NHP has no records within 1.5 miles of the service area or elsewhere on
the Highlands USGS quadrangle. Unknown populations may occur in the Highlands service area.

A.50. Mottled Trillium (Trillium discolor).
North Carolina Threatened.
Mottled trillium is locally abundant in Jackson County on circumneutral to basic soils in
rich coves of forested slopes (Amoroso, 1999). The stems are green with purple spots, the
leaves are spotted in purple and Tight green, and the pale white to cream flowers bloom from late
March to early May. NHP has no records within 1.5 miles of the service area or elsewhere on the
Highlands USGS quadrangle. Unknown populations may occur in the Highlands service area.

APPENDIX B.
Agency Scoping Comments.

North Carolina
Department of Administration
Michael F. Easley, Governor Gwynn T. Swinson, Secretary
February 20, 2002
Mr. Ward Marotti
Robert Goldstein & Associates, Inc.
8480 Garvey Drive
Raleigh, NC 27616
Dear Mr. Marotti:
Re: SCH File # 02-E-4300-0307; Scoping Town of Highlands - Wastewater Treatment Plant
Expansion from 0.5 MGD to 1.5 MGD
The above referenced environmental impact information has been reviewed through the State
Clearinghouse under the provisions of the North Carolina Environmental Policy Act.
Attached to this letter are comments made by agencies reviewing this document which identify issues to
be addressed in the environmental review document. The appropriate document should be forwarded to
the State Clearinghouse for compliance with State Environmental Policy Act. Should you have any
questions, please do not hesitate to call me at 807-2425.
Sincerely,
ehe22,
Attachments
cc: Region A
Todd Kennedy, DENR - Div. of Water Quality
aom
Ms. Chrys Baggett
Environmental Policy Act Coordinator
116 West Jones Street Raleigh, North Carolina 27603-8003 Telephone [phone]
An Equal Opportunity / Affirmative Action Employer

NORTH CAROLINA STATE CLEARINGHOUSE
DEPARTMENT OF ADMINISTRATION
INTERGOVERNMENTAL REVIEW
MS RENEE GLEDHILL-EARLEY
CLEARINGHOUSE COORD
DEPT OF CUL RESOURCES
ARCHIVES -HISTORY BLDG - MSC 4617
RALEIGH NC
REVIEW DISTRIBUTION
DENR LEGISLATIVE AFFAIRS
DEPT OF CUL RESOURCES
SWNC PLANN & ECON DEV COMM
STATE NUMBER: 02-E-4300-0307
DATE RECEIVED: 12/21/2001
AGENCY RESPONSE: 01/22/2002
REVIEW CLOSED: 01/27/2002
MT%
DEC 27 2t01
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HO
HISTORIC PRESERVATION OFFICE
PROJECT INFORMATION APPLI
CANT: Robert Goldstein & Associates, Inc. (,p/�aaCk5eP'‘-
TYPE: State Environmental Policy Act
ERD: Scoping
DESC: Town of Highlands - Wastewater Treatment Plant Expansion from 0.5 MGD to 1.5 MGD
The attached project has been submitted to the N. C. State Clearinghouse for
intergovernmental review. Please review and submit your response by the above
indicated date. If additional review time is needed, please contact this office
at [phone].
AS A RESULT OF THIS REVIEW THE FOLLOWING IS SUBMITTED:
NO COMMENT
0 COMMENTS ATTACHED
SIGNED BY:
DATE:
tUSLQ-Ecazid
c)/ 4/OR
RECEiVED
FEB " 2002
. STArE CLEARINGHQu
'JAN 1 0 2001

Ardi
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Govemor William G. Ross Jr., Secretary
MEMORANDUM
TO:
FROM:
RE:
DATE:
Chrys Haggett
State Clearinghouse
Melba McGee
Project Review Coordinator
02-0307 Scoping for Town of Highlands WWTP Expansion, Macon
County
February 20, 2002
The Department of Environment and Natural Resources has reviewed the
proposed project. The attached comments are a result of this review. -
More specific comments will be provided during the environmental review
process.
Thank you for the opportunity to respond. If during the preparation
of the environmental document, additional information is needed, the
applicant is encouraged to notify our respective divisions.
Attachments
RECEIVED
FEB 20 20621
cSTAGE CLEARINGHOUSE
1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: [phone] FAX: [phone] Internet: www.enr.state.nc.us/ENR
n.. Grni71 nnnnrit mitts \ Affirmativa Ar.tinn Fmnlnver - 50% Recycled 1 10% Post Consumer Paper

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
✓ Gregory J. Thorpe, Ph.D.
._� Acting Director
Division of Water Quality
February 13, 2002
MEMORANDUM
TO: Melba McGee
Department of Environment and Natural Resources
FROM: J. Todd Kennedy1'
Division of Water Quality
SUBJECT: Review of Scoping Letter for Town of Highlands WWTP Expansion, Macon County, DENR
#02E-0307
The Division of Water Quality (Division) has reviewed the above referenced document. The Town of
Highlands proposes to expand its wastewater treatment plant from a capacity of 0.5 MGD to 1.5 MGD. The
Division will be the lead agency in coordinating preparation of the Environmental Assessment (EA) for this
project under the NC Environmental Policy Act. Pursuant to 15A NCAC 01C.0404, the Division is
responsible for the scope, objectivity, content and accuracy of the environmental document.
A full review of alternatives to WWTP discharge expansion will be required. The EA should discuss the
existing system and need for the expansion. Flow must be justified in accordance with 15A NCAC
02H.0219, Minimum Design Requirements (http://h2o.enr.state.nc.us/admin/rules/2H.0200.pdf). The
Division's guidance for preparing the Engineering Alternatives Analysis is attached.
In order to properly consider alternatives, limits or conditions to direct discharge must be known. The
applicant must submit a speculative waste limits request to the Division prior to submittal of the EA. The
Division's response must be attached to the EA as an appendix. Contact Dave Goodrich with the Division's
NPDES Unit for more information at 919.733-5083 x517.
The NC Department of Administration's guidelines for EA preparation should be followed. In addition, the
Division requests that the following specific areas be addressed:
• Identify all streams impacted by the project including their current classification, use support
ratings and water quality;
• Discuss land use, population, zoning, development density, local land use ordinances and water
bodies within the project service area;
• Describe all changes in land use that will be induced by the project as well as associated impacts
such as increased stormwater runoff from residential and commercial development; and
• Explain how the project may affect water quality in both the Cullasaja River upstream of Lake
Sequoyah and Mill Creek, waters classified as impaired by the Division.
Discussions should cover all direct, indirect and cumulative impacts on resources in proportion to their
significance as well as proposed mitigation to avoid significant impacts. Additional guidance regarding SEPA
document preparation for Division projects can be found at http://h2o.enr.state.nc.us/sepa/index.htm.
N C. Division of Water Quality 1617 Mail Service Center Raleigh. NC 27699-1617 [phone]
NCDEi'.
Customer Servic E
1 800 623.774 e

'Town of Highlands W W'1Y hxpanston
Scoping Letter
Page 2
Once a draft EA has been completed by the applicant, one copy of the document should be submitted directly
to the Division for an initial review. The Division will review the document for format, clarity, topic and
resource coverage, and reasonable conclusions. This completeness review generally takes a minimum of two
weeks and may result in the document being returned to the applicant for necessary revisions. Next, the
document is reviewed by relevant agencies within the Department of Environment and Natural Resources
(DENR). Any issues identified during this review will need to be resolved, and the EA will need to be
amended to address the issues before DENR will support further Clearinghouse review and give project
approval under SEPA. If impacts cannot be reduced or mitigated to a level of insignificance, an EIS
(Environmental Impact Statement) will be required.
Finally, the Division encourages the town to engage the public early in the EA process. I may be contacted at
919.733.5083 x555. Thank you for the opportunity to comment on this project.
Attachment
DWQ# 12992

NC DENR / Division of Water Quality / NPDES Unit
ENGINEERING ALTERNATIVES ANALYSIS (EAA) Guidance Document
t is the Division's mandate to assure the most environmentally sound alternative be selected from all reasonably cost-
effective options. Prior to the issuance of an NPDES discharge permit, complete justification for the discharge must
be made through a comprehensive Engineering Alternatives Analysis (EAA).
The NPDES permit program was developed as a result of the Clean Water Act of 1972. The original goal of the
program (as outlined in the Act) was the elimination of all surface water point source discharges by 1985. Although
we have not achieved this goal, we continue to strive toward it. In that light,, the completion of an EAA is A
ement of an diividual or organization appl ng for a new or anding NPDES disch '(Title 15A
NCAC 2H.0105 (c) (2)). The purpose of this document is to provide guidance to the regulated community for the
evaluation of wastewater disposal alternatives. The following outline should be used in the preparation of EA►As.
In the past, the environmental feasibility and economic feasibility of a particular disposal option have been segregated.
These should not be treated as mutually exclusive analyses. They are dependent on one another. When evaluating
any of the alternatives discussed below, both environmental and economic feasibility should be addressed.
The following is an outline to be used in preparing an EAA. If any EAA submitted lacks any of these basic pieces of
information, it will be returned as incomplete.
I. General Information
A. Basicidentification of the Project
• Facility name
• County
• Facility address
• Facility telephone number
• EAA preparer's name, mailing address and telephone number
B. Provide a detailed description of the project's wastewater disposal needs. All wastewater flows associated
with this project should be calculated in accordance with 15A NCAC 2H .0219. Justification and demonstration
of need should be provided for expected flow volumes including any flow reductions realized through use of
flow restricting devices. For all alternatives, the use of flow -restricting or low -flow devices should be
investigated. A report of the findings should include flow reduction projections.
C. If existing facilities will be used as part of an expansion, discuss those existing units induding present and
past performance, unit capacities and inadequacies and provide a schematic with component sizes.
D. Indicate if the project will be constructed in phases. Provide the estimated wasteflow per phase. Indicate
current phase status for existing facilities and provide a schedule for construction of each additional phase.
II. gvaluation of Disposal Alternatives
The Engineering Alternatives Analysis should include an evaluation of any and all disposal alternatives. The
analysis should address all of the following options:
• Connection to a Publicly Owned Treatment Works (POTW)
• Connection to a privately owned treatment works
• Individual subsurface systems
• Community subsurface systems
• Drip irrigation - both surface & subsurface
• Spray irrigation
• Reuse
• Surface water discharge through the NPDES program
• Any possible combination of the above options
Engineering Alternatives Analysis: April 5. 2001
Page 1of4

NC DENR / Division of Water Quality / NPDES Unit
ENGINEERING ALTERNATIVES ANALYSIS (EAA) Guidance Document
A. Connection to a Sewer Collection System (served by a municipality or other entity holding a valid NPDES
Non -Discharge Permit).
1. Existing Sewerage System: Indicate the distance to an existing sewer line within a five -mile radius
(extension of radius should be considered if cost effective for project size).
*NOTE: All connection options should include an evaluation of both a gravity line as well as a force
main with pump station(s).
(a) Provide a description of sewer facilities and resources necessary to connect to the receiving wastewater
treatment plant
(b) Provide a preliminary indication of flow acceptance from municipal or private WWTPs under consideration for
connection. If a municipal or private WWI'P cannot accept the wastewater, please explain.
(c) Attach a topographic map or a site drawing showing the physical route of this alternative.
(d) Perform a Present Value of Costs Analysis for this alternative as outlined in Appendix A of this document.
Investigate cost -sharing options with other potential users.
2. Planned Sewerage System: Determine if an area wide sewerage system within a five mile radius is
projected to be available within the next five years to receive waste from the project under study.
Determine availability date and flow acceptance projection with appropriate authority. Identify your
contact in the public utility or private management group that assisted you in this determination.
B. Land Based Disposal (Installation of nitrification systems, low pressure pipe systems, drip irrigation, mound
systems, and spray irrigation systems).
1. Determine if the applicant currently owns land that is available and suitable for a subsurface system.
(a) Provide a description of the facilities and resources necessary including a site plan indicating the proposed
layout.
(b) Provide a soil analysis that includes the information outlined in Appendix B of this document
(c) Provide calculations to determine the disposal capacity of the applicant's available land, based on design and
loading rate characteristics as well as appropriate regulations.
(d) Describe what modifications to the plan (such as reducing the number of units produced,- the reduction of
design flow, etc.) would be necessary to allow for adequate disposal using usable land on the site. .This step
should be performed if there is insufficient usable land, considering the existing project development plan. If
there is not sufficient usable land, explain why not.
(e) Perform a Present Value of Costs Analysis for this alternative as outlined in Appendix A of this document
2. If there is insufficient land on the project site, determine if any additional land could be acquired.
Provide documentation of availability. If adjacent land could be acquired, evaluate according to item B
(1). If adjacent land is unavailable, provide documentation from the owner stating such.
NOTE: Subsurface disposal systems require a 100% reserve area. Surface disposal systems must be
capable of treatment to secondary limits including disinfection. •
C. Wastewater Reuse Evaluate reusing all or a portion of the wastewater generated on -site.
D. Surface Water Discharge (a discharge to a flowing stream - defined as having positive 7Q10 and 30Q2 flows).
1. USGS should be consulted for obtaining receiving stream flow information. This information should be
provided in conjunction with treatment plant design. For flow information contact Mr. Curtis Weaver at
[phone].
2. All discharging systems should be evaluated both with and without tertiary filtration assuming a weekly
sampling regime.
3. Provide a description of the proposed discharge facilities, including a schematic diagram of the major
components and a site plan of the treatment facility with outfall line(s). All discharge systems must meet
design criteria outlined in the Division's "Authorization to Construct Process."
4. Provide documentation of the availability of required land and/or easement agreements.
5. Perform a Present Value of Costs Analysis for this alternative in accordance with Appendix A of this
document.
Engineering Alternatives Analysis: April 5, 2001
Page 2 of 4

1.2
d�
0 E. Disposal Combinations: The EAA should evaluate the feasibility of a combination of any of the above
disposal alternatives in lieu of a surface water discharge.
NC DENR / Division of Water Quality / NPDES Unit
ENGINEERING ALTERNATIVES ANALYSIS (EAA) Guidance Document
Appendix A
Present Value of Costs
The Present Value of Costs Analysis (PVCA) is meant to evaluate. all costs . associated with a particular disposal
alternative over the life of the project. • Prior to performing a PVCA for any of the alternatives, all costs must be
identified The PVCA should include all monetary costs associated with construction, startup and operation of a
facility. Costs should include, but not be limited to, the following.
Capital Costs
• Land acquisition costs
• Equipment costs
• Labor costs
• Installation costs
• Design costs
Recurring Costs
■ Operation and maintenance costs (with replacement costs)
■ Laboratory costs assuming a weekly monitoring regime for discharge. systems and a. monthly regime for non -
discharge systems
• Operator and support staff costs
■ .. Residual disposal costs
• . Connection and subsequent user fees
• : Permit and compliance fees
• Utility costs (power, water, etc.)
Opportunity Costs
NOTE: All cost information provided must be referenced. If vender quotes have been
received for treatment units or other components, thcy shall be included as well.
Present Value of Costs
Costs incurred in different time periods must be converted to a common time period before they can be accurately
combined or compared. Performing this calculation is known as "computing the'present value," or "discounting" the
costs. Present value is also sometimes called "present discounted value" or "present worth".
The following standard formula for computing the present value must be used in all cost estimates made under this
evaluation guidance:
Where:
PV=C +t=
° , (1+rY
PV = Present value of costs. Co = Costs incurred in the present year.
Ct = Costs incurred in time t. t = Time period after the present year ( The present year is t = 0)
n = Ending year of the life of the facility.
r = Discount rate. For these calculations, an interest rate quoted by the lending institution should be used.
The interest rate quote should be provided with this analysis.
Engineering Alternatives Annlusis: Agri! 5. 2001

NC DENR / Division of Water Q.:I:stir.
ENGINEERING ALTERNATIVES ANALYSI
However, if the costs are the same in every time period from year one thro
1,2,..., n), then the formula reduces to:
PV=Co+C
(1 + r)" —1 l
r(1+r)" J
In this case, the present value may also be looked up in a table containing the present value of auniu. _.;, ,,.
constant amount payable in each year for a certain number of years). Such tables are available.:
.o
institutions.
Appendix B
Soil Analysis Report Requirements
For all new facilities
The EAA must include a detailed soil analysis report including, but not be limited to, the following:
• A copy of field notes and boring log information
• A soils site map overlain on a topographic map (county soil maps may be used for delineating boring
locations only, not for soil characterization).
• Soil characterization in terms of texture, structure, permeability, wetness and mineralogy
• Soil characterization to a depth of 48" or to a restrictive horizon
• Soil loading rate recommendations and land area requirements
The report should address the applicability of any surface or subsurface disposal alternative.
For existing facilities proposing an expansion
The EAA must include a detailed soil analysis report including, but not be limited to, the following:
■ County soil maps used to identify on -site soils.
• Best -case loading rates using these soil characterizations.
• PVCA (see above).
If the present value for a non -discharge alternative is less than for a discharge system, provide a more detailed soil
analysis report including the following:
• A copy of field notes and boring log information
• A soils site map overlain on a topographic map (county soil maps may be used for delineating boring
locations only, not for soil characterization).
• Soil characterization in terms of texture, structure, permeability, wetness and mineralogy
• Soil characterization to a depth of 48" or to a restrictive horizon
■ Soil loading rate recommendations and land area requirements
Engineering Alternatives Analysis: April 5. 2001
Page 4 of 4

North Carolina Wildlife Resources Commission
512 N. Salisbury Street, Raleigh, North Carolina 27604-1188, 919-733-3391
Charles R. Fullwood, Executive Director
MEMORANDUM
TO: Melba McGee, Environmental Coordinator
Office of Legislativ d Int e ental airs
FROM: Owen F. Anderson,
ntReg ion Coordinator
u
Habitat Conservation Program
DATE: February 11, 2002
SUBJECT: Scoping for Town of Highlands WWTP, Macon County, North Carolina, DENR
No. 02E-0307
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 Town of Highlands proposes to expand the wastewater treatment plant to serve the
Town of Highlands and five annexation areas. The expansion will triple treatment capacity from
0.5 to 1.5 million gallons per day. There is no reference to expansion of the collection systems;
however, the scoping letter refers to an annexation area.
There are significant aquatic and terrestrial resources within the affected area of this
project. Most of the affected area appears to be in the Cullasaja River watershed but some
impacts may occur within the Chattooga River drainage. Both of these streams support
significant aquatic resources. In the Highlands area, many of the streams within these two basins
are either classified by the Division of Water Quality as trout waters or are designated trout -
waters by the NCWRC. Additionally, Big Creek, Lake Sequoyah and a portion of Mirror Lake
are classified as WS-III tr HQW. Additionally, the streams in the area provide significant
recreational opportunities.
The North Carolina Natural Heritage Program identifies a number of natural heritage
elements for the Highlands area. These elements are both on public and private lands and
include plants, animals and community types. For example, there is a Southern Appalachian bog
near one annexation area. And a record for a bog turtle (Clemmys mulenbergii) in the vicinity of

Town of Highlands WWTP 2
Macon County, Cullasaja & Chattooga Rivers
February 11, 20o
this annexation area in a different location than the bog. Bogs provide important habitat for fish
and wildlife other than the State and federally threatened bog turtle. Since this project could
adversely impact a federally threatened species, we request that the project sponsors or their
consultants consult early in the project with the U.S. Fish and Wildlife Service. The Service can
be contacted in Asheville at [phone].
We believe this project has the potential to have significant adverse impacts to fish and
wildlife resources, including listed species. The impacts could result from additional effluent
and associated pollutants, extension of sewer lines and crossings; however, the greater concern is
the secondary and cumulative impacts associated with a significant increase in infrastructure.
Direct impacts of concern primarily relate to discharge of additional effluent,
malfunctioning pump stations and treatment plant and discharge of toxic substances (e.g.,
chlorine). We request that expanding wastewater treatment plants be equipped with a non -toxic
disinfecting method such as ultraviolet light. Additionally, we request that all pump stations and
the WWTP be equipped with standby emergency generators of sufficient size to maintain the
critical parts of the conveyance and treatment works during power outages. We do not consider
dual feed- power to constitute an emergency power supply.
The increased infrastructure is likely to lead to growth in an already rapidly growing area.
An increase in impervious surfaces, filling of floodplains, loss of wetlands, fragmentation of
habitat and loss of forested riparian buffers are impacts typically associated with expanding
water or sewer infrastructure. Gravity sewer lines can have significant adverse impacts on
streams if their installation results in disturbances and canopy removal in close proximity to the
stream. Therefore, locating gravity sewers and pump stations as far away from streams as
possible is extremely important. Sediment is a major water pollutant and tends to increase with
growth and development of an area and is a major concern already in the Highlands area. Golf
course developments are particularly environmentally offensive and are of special concern.
The information provided is not sufficient for our staff to make definitive
recommendations or conclusions concerning this project. Due to staff limitations, this
standardized response was developed for projects such as this. Although some of the
information, requests and comments may not be applicable to certain projects, these guidelines
should facilitate preparation of fish and wildlife impact assessments. This information will be
very useful if it becomes necessary to prepare an environmental document.
In addition to addressing the concerns discussed above, the environmental document
should include a detailed assessment of existing natural resources within these areas of potential
development and should discuss the potential of mitigating development impacts to wetlands,
surface waters and high -quality upland habitat. Additionally, to provide a meaningful review of
proposed project impacts on fish and wildlife resources, we request that consultants, project
sponsors or permit applicants provide the following information in the environmental document.
1. Include descriptions of fish and wildlife resources within the project area, and a listing of
federally or state designated threatened, endangered or special concern species. When

9.. ..�
erb
Gi 9.‘,�, of Highlands WWTP 3
acon County, Cullasaja & Chattooga Rivers
February 11, 2002
practicable, potential borrow or disposal areas to be used for project construction should
be included in the inventories. A listing of designated species can be developed through
consultation with: The Natural Heritage Program, NC Division of Parks and Recreation,
1615 Mail Service Center Raleigh NC 27699-1615, PH: [phone].
2. Include descriptions of any streams or wetlands affected by the project.
•
3. Include project maps identifying wetland areas. Identification of wetlands may be
accomplished through coordination with the U.S.. Army Corps of Engineers (COE). If
the COE is not consulted, the person delineating wetlands should be identified and
criteria listed.
4. Provide a description of project activities that will occur within wetlands, such as fill or
channel alteration. Acreage of wetlands impacted by alternative project designs should
be listed.
5. Provide a description and a cover type map showing acreage of upland wildlife habitat
impacted by the project.
6. Discuss the extent to which the project will result in loss, degradation or fragmentation of
wildlife habitat (wetlands and uplands).
7. Discuss any measures proposed to avoid or reduce impacts of the project or to mitigate
unavoidable habitat losses.
8. Discuss the secondary and cumulative impacts associated with the proposed project.
Such discussion should weigh the economic benefits of such growth against the costs of
associated environmental degradation.
(a) Include specific measures that will be used to manage stormwater runoff. Include
specific requirements for residential, commercial and industrial developments and
BMPs that will be required.
(b) Include specific measures that will be used to protect stream corridors, riparian
habitat and a minimum of the 100-year floodplain from filling and development.
. Commitments by the project sponsors to protect area streams with riparian buffers
through purchase or conservation easement are of particular interest.
(c) Include specific measures that will help mitigate the impacts to fish and wildlife of
the region and help maintain the functions of the Cullasaja and Chattooga drainages.
9. Include a list of document preparers that shows each individual's professional background
and qualifications.
Measures to avoid or minimize impacts to sensitive resources, including wetlands, should
be implemented during construction. Where impacts to wetlands are unavoidable, we will

Town of Highlands WWTP 4
Macon County, Cullasaja & Chattooga Rivers
February 11, 2002
recommend mitigation of the losses. In addition to providing wildlife habitat, wetland areas
perform important functions of flood control and water quality protection.
To avoid or minimize wetland impacts, we offer several generalized recommendations.
Utility lines should be placed in or adjacent to upland areas. It is recommended that a minimum
100-foot buffer of forested vegetation be left between construction corridors and the banks of
larger perennial streams. These buffers will help minimize impacts to water quality, stabilize
streambanks and provide travel corridors. for wildlife. Native trees and shrubs should be retained
or established in the buffers. Forested buffers should also be left along intermittent drains or
streams.
The U.S. Army Corps of Engineers (COE) recognizes Macon County as a trout county
and most of the streams in the project area do support trout. Therefore, the NCWRC will review
any COE permits associated with the project and recommend conditions to the permit to protect
aquatic species. In -water work moratoriums to protect trout and/or endangered species will
likely be requested.
Thank you for the opportunity to provide input in the early planning stages for this
project. If we can be of further assistance, please contact our office at [phone].
cc: Steve Hall, Zoologist, Natural Heritage Program
Brian Cole, Biologist, USFWS Asheville

AT;Til
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Parks and Recreation
Michael F. Easley, Governor William G. Ross, Jr., Secretary Dr. Philip K. McKnelly, Director
January 22, 2002
MEMORANDUM
TO: Melba McGee
FROM: - Stephen Hall c
SUBJECT: Scoping — Wastewater Treatment Plant Expansion, Highlands
REFERENCE: 02E-0307
The Natural Heritage Program database contains records for several rare plants and animals from the
Cullasaja River and its near vicinity downstream from the Highlands WWTP. Also located
downstream is the Cullasaj a Gorge Registered Natural Area and the highly significant botanical site
at Dry Falls. We strongly recommend that direct impacts to these resources be considered, including
the effects of sedimentation, increased pollutant discharge, and changes in flow regime.
Additionally, since the proposed project may allow additional growth within the Highlands area, we
recommend that secondary and cumulative impacts be considered relative to the large number
rare
species and natural areas that are located throughout the service area of the WWTP.
1615 Mail Service Center, Raleigh, North Carolina 27699-1615
T- n,n -rIc )CQ \ T t y-,Ar• ujww nrcnarkc net

•
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL HEALTH
Inter -Agency Project Review Response
Project Name
ra
•
Project Number
4.107
County
Type of Project
The applicant should be advised that plans and specifications or all water system
improvements must be approved by the Division of Environmental Health prior to the
award of a contract or the initiation of construction (as required by 15A NCAC 18C
.0300et. seq.). For information, contact the Public Water Supply Section, (919)
733-2321.
❑ This project will be classified as a non -community public water supply and must comply
with state and federal drinking water monitoring requirements. Formore information -the
applicant should contact the Public Water Supply Section, [phone].
❑ If this project is constructed as proposed, we will recommend closure of ___ feet of
adjacent waters to the harvest of shellfish. For Information regarding the shellfish
sanitation program, the applicant should contact the Shellfish Sanitation Section at (252)
726-6827. -
•
❑ The soil disposal area(s) proposed for this project may produce a mosquito breeding
problem. For information concerning appropriate mosquito control measures, the
applicant should contact the•Public Health Pest Management Section at [phone].
❑ The applicant should be advised that prior to the removal or demolition of dilapidated
structures, a extensive rodent control program may be necessary in order to prevent the
migration of the rodents to adjacent areas. For information concerning rodent control,
contact the local health department or the Public Health Pest Management Section at
[phone].
❑ The applicant should be advised to contact the local health department regarding their
requirements for septic tank installations (as required under 15A NCAC 18A. 1900 et.
sep.). For information concerning septic tank and other on -site waste disposal methods,
contact the On -Site Wastewater Section at [phone].
❑ The applicant should be advised to contact the local health department regarding the
sanitary facilities required for thisproject.
if existing water lines will be relocated during the construction, plans for the water line
relocation must be submitted to the Division of Environmental Health, Public Water
Supply Section, Technical Services Branch, 1634 Mail Service Center, Raleigh, North
Carolina 27699-1634, [phone].
❑ For Regional and Central Office comments, see the reverse side of this form.
me,14a,
Reviewer
Section/Branch Date
a

•
lY
ucr/-1r1 I Ivicii I lJr clv v ff"tVIVlvlciv I I-\Iyu
NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL HEALTH
Inter -Agency Project Review Response
1
Project Name vT ���J Type of Project
i/
Comments/44,,-
provided by:
❑ Regional Program Person
.g Regional Engineer for Public Water Supply Section
❑ Central Office program person
Name:
Telephone number.
Program within Division of Environmental Health:
Public Water Supply
❑ Other. Name of Program:
Response (check all applicable):
❑ No objection to project as proposed
❑ No comment
❑ Insufficient information to complete review
❑ Comments attached
❑ See comments below
Project Number
D Z£ -d,�a
GtI TP fo vfi�•,.
›4› e*K
Date:
0 6 “. a/1 -115
J � � J
AiNcOn S 6 e.101.0
L 4 KL ✓o� 7 L7
,S f-A-1174J1
WI 7-r51,ti-rC .
ice. Me.M.-1
5 lo,t S S G1 i3 cL '- G.
c.J t ti 5 cf i )C 4S 1Ct, v 4M.
Retum to:
Public Water Supply Section - 7
Environmental Review Coordinator for the
Division of Environmental Health

Memorandum
11 March 2002
To: Joe Corporon
From: Andrea Leslie, Watershed Assessment and Restoration Project
cc: Callie Dobson, Little Tennessee River Basin Planner
Subject: 7Q10 in the Upper Cullasaja River
There has been much public concern about the potential water quality impacts of Highlands'
wastewater treatment plant, which has been on the Cullasaja River since 1994. The Division
of Water Quality used equations and assumptions developed by USGS (Giese and Mason,
1991) to estimate 7Q10 flows to permit this wastewater treatment plant. Highlands is
currently preparing to expand their wastewater treatment plant. When this permit request is
processed through the Division of Water Quality, it will be important to use a 7Q10 that
reflects the hydrology and land use of the Highlands Plateau.
I understand that the 7Q10 estimations from the USGS document are intended to
approximate low flows in non -urban and unimpounded streams. The Cullasaja River and its
tributaries are dammed numerous times above Highlands' wastewater treatment plant, and
Highlands is a sprawling developed area. Evaporation from impoundments, withdrawals of
water by numerous golf courses, and impervious surface all reduce the amount of baseflow
in the Cullasaja River. It is important that the Division of Water Quality factors these
components into its 7Q10 estimation for the Cullasaja River.
Giese, G.L. and R.R. Mason. 1991. Lowflow characteristics of streams in North Carolina.
USGS Open -File Report 90-399. Raleigh, NC.

APPENDIX C.
Public Scoping Comments, Public Meeting Minutes, and Affidavit of Publication.

PUBLIC HEARING of January 30, 2002, with Mayor Buck Trott and
Commissioners H. N. James, Ron Sanders, Amy Patterson, Mike
Cavender, and Hank Ross present.
Also present were Richard Betz, Lamar Nix, Kurt Wright, Bob
Goldstein, Ward Maroti, Kim Lewicki, Don Hendershot, Buzz
Williams, Pat Boyd, Henrietta Norman, Clement Patton, Peg Jones,
Jody & Carolyn Cook, Gerry Doubleday, Bob Wright, Peter Lintz,
Edna Foster, Lee Byers, Katie Chenoweth, Jeremy Dooley, Robert
Wyatt, Bill McLarney, Jim Graham, Shirley Johnson, and Jack
Bornemann.
The Mayor called the Public Hearing to order at 7:00 p.m. He
explained that the purpose was to hear a presentation from the
Town's consulting engineer and environmental scientist, and to
answer questions and receive comments from the public, on the
Town's proposed expansion of the capacity of its existing 0.5
million gallons per day (MGD) Wastewater Treatment Plant (NPDES
Permit No. NC0021407) to 1.5 MGD. The public hearing had been
duly advertized for this time and place.
Each Board member had received copies of a Preliminary
Engineering Report dated January 21, 2002, prepared by W. K.
Dickson Company Inc., and copies were also available for the
public. Several maps and plans from the report were displayed in
the hearing room. The Mayor then introduced Kurt Wright, P. E.,
from W. K. Dickson Co., and Bob Goldstein and Ward Maroti of
Robert J. Goldstein & Associates.
Kurt Wright proceeded to present an overview of the project,
including the basic design of the existing Sequential Batch
Reactor (SBR) facility, constructed in 1994 and permitted in
1999; the NPDES permit was scheduled to expire October 31, 2002,
and the permit application would need to be submitted 180 days
prior to that date. Because of the expectation of increased
effluent limits, a decision had been made to go to tertiary
treatment; although the effluent limits had still not been
released by the Department of Environment and Natural Resources
(DENR), it was likely that the tertiary treatment would meet
those standards. He then reviewed the combination of 20year
population projections and existing flow records used in the
report, which indicated an average design flow for the period of
1.5 MGD. Four alternatives had been explored: Option 1,
Expanding the plant, with 100% surface water discharge of
effluent; Option 2, spray irrigation of treatment plant effluent;
Option 3, connecting to the Franklin or Cashiers systems; or
Option 4, reusing the effluent at area golf courses. Option 1
was the most costeffective option.
Bob Goldstein then introduced himself and his firm, which had
specialized in environmental documents since 1985, and briefly

described the requirements under the State Environmental Policy
Act, which required preparation of an environmental document when
public funds were spent. He said that the Environmental
Assessment (EA) was a formal document that would be reviewed by
several state agencies, with the hope that all of the agencies
would eventually agree to a Finding of No Significant Impact.
The EA was now in its scoping phase, with comments from the
agencies due by February 15; those comments and recommendations
would be incorporated into the EA. The EA would also address the
environmental setting, the need for the expansion, disposal of
effluent, and other environmental concerns. By trying to
anticipate all possible recommendations and alternatives, it was
expected that the process could be accelerated, and also that all
of the issues could be addressed and damages avoided far more
effectively than through an Environmental Impact Statement (EIS).
He also said that one of the key components of the EA would be an
analysis of what the Town was doing to control growth and
mitigate the effects of growth through its land use program.
Ward Maroti reported that most of the work was complete, and that
the completed draft would be ready in a matter of weeks.
Kurt Wright then reviewed in more detail the treatment process in
the proposed project, which would include two new SBR tanks, new
filters, and ultraviolet treatment, with chlorine as a backup.
Bob Goldstein commented that the quality of water with tertiary
treatment would be pretty close to potable.
Mr. Wright then fielded several questions on the presentation.
Gerry Doubleday asked about the flow in the Cullasaja River. Mr.
Wright explained that the effluent limits would be based on the
low flow, or "7Q10" in the river; when in full operation, he
expected the plant would discharge no more than one tenth the
flow in the river under driest conditions. Jim Graham asked
about the quality of water in the river, and Mr. Wright explained
that it would not have any adverse effects. Buzz Williams asked
about the effects of stormwater, and Mr. Wright explained that
due to an aggressive inflow and infiltration program, the Town
had eliminated this problem.
The Mayor then invited each of the five persons who had signed up
to speak to be heard.
Buzz Williams, representing the JacksonMacon Conservation
Alliance, commented that he had yet to see a sewage treatment
facility that worked properly. He was concerned about the
possibility of lowering water quality in the Cullasaja River,
which he felt should be an outstanding resource water, not just a
BTrout river. He asked the Board to consider endorsing the
State's Natural and Scenic Rivers designation anfor
ehe river
emont
recognize and protect it, and he felt that such
would not hamper the expansion of the Plant.

Peg Jones asked William McLarney, who had not signed up, to speak
before she did. Dr. McLarney said that, although he had not
planned to speak, he would make some comments on behalf of the
Little Tennessee Watershed Association. He said that while he
agreed a dose of skepticism was in order, he was impressed by the
project; he had always felt that tertiary treatment was a good
idea. He also said that he was concerned about water quality in
the area between Lake Sequoyah and Dry Falls. But he felt that
basically the project was a good start in the right direction.
Peg Jones, representing Save Our Rivers Inc., thanked the Board
for going through this process. She said she had come with a
prepared statement, but was not going to read it; she felt that
the tertiary treatment would be effective in cleaning up the
river. She also expressed some concerns over the increasing
growth in Highlands, and reiterated Mr. Williams's earlier
request for endorsement of the Wild & Scenic River designation.
She commented that this permit process was being closely watched,
but thanked the Board for its courtesy in holding the hearing.
Jodie Cook, representing the Upper Cullasaja Watershed
Association, also commented that tertiary treatment was an
excellent choice, as was the SBR design. He was pleased to see
this technology in use.
Peter Kintz, representing the JacksonMacon Conservation
Alliance, noted that the Cullasaja River and some of its
tributaries above Lake Sequoyah were listed as impaired. He was
impressed by the presentation, however. He asked when DENR's
effluent limits would be released. Mr. Wright said he understood
they would be available soon, and the information would be
available to the public.
Bob Wright, representing the Upper Cullasaja Watershed
Association, thanked the engineers for the professional
presentation. He wondered about the NPDES permits in the entire
river basin being due at the same time and the effect that might
have. He also pointed out that most of the studies of water
quality in the river had been based on microinvertebrate studies,
but he was interested in water chemistry testing as well. He
also felt detecting and handling upset conditions should be addressed.
The Mayor thanked those present for their comments. He also
pointed out that, just because the Town was planning to expand
its plant, that did not indicate there was anything wrong with
the Town's existing plant or operations. He said that it was
continuing to meet all limits, sampling was conducted by
independent contractors, and the facility employed the best
operators in the business. He asked if there were any other
comments.

Buzz Williams commented that the NPDES reporting system relied on
monthly averages, and daily spikes would not show up. He was
also concerned that decisions would be made before DENR's
effluent limits were released. Mr. Wright assured him that the
effluent limits were due soon, and no decisions would be made
before they were established.
Dr. McLamey commented, in general, that he had detected a
considerable increase in pollution in several of the tributaries
to the river; anything that could be done that would protect the
river would benefit everybody.
There being no further comments from the public, the public
hearing was declared adjourned by the Mayor at 8:20 p.m.
Richard Betz, Town Clerk

Affidavit of Publication
Clipping of Legal Advertisement here
:wip'J • hie d on
4,i ygip....11101.107.
►•k;oa3
gluerwaRrmuliFY
r• •
North Carolina
-Macon County
Before the undersigned, a Notary Public of said County
and State, duly commissioned, qualified and authorized
by law to administer oaths personally appeared
cticitoir)
who being first duly sworn, deposes and says: that she /he
is
€mpk4Q cLU-41Yf?Qd
(Owner, partner, publisher, or other employee authorized
to make this affidavit) of The Highlander Newspaper, pub-
lished, issued and entered as second class mail in the Town
of highlands in said County and State; that she/he is au-
thorized to make this affidavit and sworn statement; that
the notice or other legal advertisement, a true copy of which
is attached hereto, was published in The Highlander News-
paper on the following dates:
rkcsyrn ar)
;15
�in which such not apes
and that the said newspaper , paper,
,
document or legal advertisement was published was, at
the time of each and every such publication, a newspaper
meeting all the requirements and qualifications of Section
I-597 of the General Statutes of North Carolina and was a
qualified newspaper within the meaning of Section 1-597
of the General Statutes of North Carolina.
r
This (5 day of Q!)11)(1620 C»--
G.�UAL,.
Signature of person making affidavit
Sworn to and subscribed before me,
this Rel day of !�)C)�
erPp
My Commission Expires
Notary ublic
My Commission Expires April 30, 2003

941mA/ asai{-n{_ , 9/Vale/vs/led Msso/ciatiart
P.O. Box 1508 - Peggy Crosby Building
828-526-9938 x23
Highlands, NC 28741
February 12, 2002
To: The Town of Highlands
W. K. Dickson & Co. Inc.
From: The Upper Cullasaja Watershed Association, Inc.
Subject: Comments to the Preliminary Engineering Report
For the Town of Highlands
Wastewater Treatment Plant Expansion,
January 21, 2002
re: Environmental Assessment Scope
The Upper Cullasaja Watershed Association, Inc., of Highlands, NC, is a non-profit, citizen -based
organization dedicated to the analysis of water quality and water quantity issues in the 15 square mile
watershed upstream of the Lake Sequoyah dam. Incorporated in 1999, UCWA has systematically
approached water resource issues on the Highlands Plateau by developing partnerships and projects
to improve scientific instrumentation and measurements to bring data -based observations and
recommendations to the community to improve understanding and to support better decision
processes. UCWA's achievements include the restoration of USGS streamgaging measurements in
the Cullasaja River, expanded rainfall measurements in a network of instruments in the watershed,
and cooperative development of a 5-year ground water study by the USGS and the State of NC,
DENR.
The State of North Carolina is currently in the process of publishing the 2002 update of The Little
Tennessee River Basinwide Water Quality Management Plan. As stakeholders in the review
process, UCWA references the following findings of the basinwide planning process which are
relative to the Cullasaja River and germane to the NPDES permit renewal for the Highlands waste
water treatment plant (WWTP).
1. The 4.8 miles of the Cullasaja River headwaters upstream of Mirror Lake Rd ( SR 1545)
and 1.4 miles of Mill Creek from the source to Mirror Lake are classified by the State of NC as
impaired waters. The source of impairment is nonpoint source pollution, principally sedimentation.
These findings and classifications are based primarily on benthic macroinvertebrate studies and
bioclassifications of these streams.
2. The Cullasaja River watershed was given special attention by Division of Water Quality
biologists in 1999 (ed. following the latest NPDES discharge permit renewal). "Benthic
macroinvertebrates were sampled at four mainstream river sites and seven tributaries. All Cullasaja
River sites downstream of Highlands were Excellent DWQ biologists concluded that no
substantial changes in water quality have been observed since the river was first sampled in 1990."
UCWA believes that these results provide strong evidence that water quality in the Cullasaja River
downstream of Lake Sequoyah has not been adversely impacted by the operations of the Highlands
WWTP.
Page 1 of 3

UCWA Comments to the Preliminary Engineering Report
for the Town of Highlands WWTP Expansion
3. With respect to the Cullasaja River's aquatic life and recreation use support classifications,
the basinwide plan states that the impaired streams above Mirror Lake are "Partially Supporting" and
the Cullasaja River "from the dam at Lake Sequoyah to the Little Tennessee River" is "Fully
Supporting". Big Creek is also "Fully Supporting".
4. With respect to the public water supply use support classifications, the Cullasaja River and
Mill Creek upstream of Lake Sequoyah are "Fully Supporting".
Missing from the State's data are water chemistry analyses of the Cullasaja River and Lake Sequoyah.
DWQ staff are currently summarizing the findings of the Watershed Assessment and Restoration
Project conducted in the watershed for the past 2 years. The report and DWQ's recommendations
are to be published in March of 2002. Again, the emphasis has been on benthic macroinvertebrates
sampling with some water chemistry correlations. All sampling sites, however, have been upstream
of Lake Sequoyah. We know of no current water chemistry data for Lake Sequoyah or the Cullasaja
River immediately downstream of the WWTP discharge point. Aquatic life and fish studies, however,
continue to indicate that water quality downstream of Lake Sequoyah (particularly the river below
the Cullasaja Falls on US 64) is Excellent.
UCWA is pleased to learn that the Town and W.K. Dickson are providing tertiary waste water
,treatment processes and ultraviolet radiation treatment for the proposed expansion to further improve
the water quality of the effluent discharged from the plant. Reviewing the Preliminary Engineering
Report, we note that the effluent specifications are not presented. We request the water chemistry
specifications for the treated effluent be defined in the report for the recommended process,
regardless of the permit limits to be set by the State of North Carolina. Further, we believe that the
public will be better informed by a direct comparison of the current SBR plant's effluent data
(specifications and measurements) with the recommended expansion process specifications. Both a
quantitative and qualitative analysis of this comparison should be discussed in layman's terms for the
public.
Additionally, UCWA recommends that the environmental assessment for the NPDES permit renewal
application specifically test water chemistry parameters in Lake Sequoyah above the dam, in the
effluent stream, and in the mixed flow regime downstream of the current WWTP discharge point.
Scientific analysis and comparison of the water quality data from these three points can be used to
inform the public about the true performance of the WWTP. The findings should also be related to
water suitability for human contact ( recreation, swimming, etc.) in all three streams. These studies
are recommended for both the current and the expanded plant discharge conditions. For example,
should these analyses show that the quality of the discharge effluent is higher than that of the lake and
river, it would be impossible to conclude that the WWTP is producing any negative effects in the
river. Findings such as this would be consistent with DWQ's macroinvertebrate bioclassifications and
the use support ratings downstream of the Lake Sequoyah dam.
Page 2 of 3

UCWA Comments to the Preliminary Engineering Report
for the Town of Highlands WWTP Expansion
Finally, UCWA recommends that W. K. Dickson and its environmental consultant evaluate the
technical feasibility and potential benefits of moving. the effluent discharge point from its current
location to re -inject the tertiary -treated wastewater stream upstream of the Lake Sequoyah dam. This
alternative has significant benefits with respect to demonstrating the Town's good faith efforts
towards the public downstream of the plant.
UCWA believes that with the improved water quality resulting from tertiary -treated waste water,
reinsertion into Lake Sequoyah is both technically feasible and desirable as a demonstration of the
Town's confidence in the operations of its wastewater treatment plant. If the discharge point is
located relatively near the dam (say, within 100 yards) significant mixing and dilution can still be
achieved prior to the water flowing over the dam to the river below. Any new public water supply
intake pumping will be located further upstream in Lake Sequoyah; therefore, only a complete
reversal of Cullasaja River flow could possibly result in any mixing of the diluted effluent stream with
the intake.
In addition to evaluating the alternative of moving the discharge point upstream into Lake Sequoyah,
UCWA recommends that the W.K. Dickson include in this analysis an evaluation of any potential
impact on the Lake Sequoyah's classification as a Public Water Supply Reservoir.
UCWA believes that the additional studies and measurements recommended in these comments
are
essential to the public's understanding of the proposed expansion and the WWTP's relicensing. We
appreciate this opportunity to include our comments in the ongoing process.
cc• ' obert J. Goldstein & Associate
Robert K. Wright,
Vice President & Executive Director
Upper Cullasaja Watershed Association, Inc.
A 501 (c)(3) corporation
Page 3 of 3

To Whom It My Concern:
My name is Peg Jones. I serve as president of Save Our Rivers, Inc.
We appreciate the town of Highlands conducting for the public this
informational meeting regarding the proposed expansion of the town's
sewage treatment plant from .5mgd to 1.5mgd, with discharge into the
Cullasaja River, in the Nantahala National Forest.
One question to be considered is, if the town wants to grow, : can it afford
to do so without jeopardizing the existing water supply? The Upper Culasaja
Watershed Association is to be commended for trying to educate the public
on the supply of water on the Highlands Plateau. A pie can be cut into only so
many pieces. Without water, even million dollar homes will be useless and
have no value.
The Clean Water Act, passed in 1972, under President Nixon, called for our
nation's rivers to be swimmable and fishable by 1983. A major component of
the CWA is the Antidegradation Policy, which does not allow any prior uses
of a waterway to be taken away. The Cullaasaja River, listed on the
Nationwide Rivers Inventory, has been known through the centuries for its
being used for purification, baptisms, swimming, boating, its well -
documented flora and fauna biodiversity, and its scenic and natural beauty. It
has been nominated for state designation of Natural and Scenic, and federal
Wild and Scenic.
The law is on the books to protect our waterways, both upstream and
downstream.
We will be more than glad to work with you and share with you sample
documents, including a small pamphlet from the City of Durham, "25 Things
to Do to Prevent Water Waste", Second Nature, the story of Los Angeles'
use of alternative methods to conserve water and prevent flooding, rather than
further desecrate its inner city river, and the state's Natural and Scenic River
Feasibility Study and Recommendations for the Cullasaj a River.
This permit process is being closely watched. We hope that all means will be
used to do what is right for all and set an example for others.
Thank you.

APPENDIX D.
Speculative Effluent Limits for the Highlands WWTP Expansion,
NPDES Permit NC0021407, Macon County, NC

Michael F. Easley, Govemor
State of North Carolina
`*G William G. Ross, Jr., Secretary
fA Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Mr. Richard Betz
Town Administrator
P.O. Box 460
Highlands, North Carolina 28741
June 28, 2002
Subject: NPDES Permit application NC0021407
Highlands WWI P
Macon County
Return #2167
Dear Mr. Betz:
The NPDES Unit received your application for an expansion at the Town of Highlands W' TP. This
package was previously submitted and returned by the Division because it was submitted without a Finding
of No Significant Impact (FONSI) and speculative limits. The speculative limits have been completed and are
expected to be issued by mid July.
As it was previously explained, the Division can not accept an expansion request before the State
Clearinghouse reviews the Environmental Assessment and issues a FONSI. The Environmental Assessment
(EA) for the Town of Highlands has not been received for review by the Division as of June 26, 2002. The
process of reviewing the EA and issuing the FONSI has not begun yet, so it is difficult to predict how long it
will take since it depends greatly on the magnitude of the project, the public interest and the impact of the
project. In average, an EA review can take 5 to 6 months if there are no significant comments. For this
reason, the Engineering Alternative Analysis must be returned.
The application submitted will be accepted as the renewal application. The Engineering Alternative Analysis
is hereby returned. Once the FONSI is issued, the expansion request can be resubmitted. At this time a fee
of $400.00 will apply.
If you have any questions concerning this request, please call me at [phone], extension 595.
Sincerely,
C2/(A-
Teresa Rodriguez
NPDES Unit
Cc: NPDES Files
Kurt Wright — WK Dickson
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[phone] NCDENR
FAX [phone] Customer Service
On the Internet at htto://h2o.enr.state.nc.us/ 1 800 623-7748

9-04-202 1 1: 2SAI t FRO' t
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
•
Mr. Diehard Betz
Tows ' . • ' • trator
rth Carolina 28741
tn< g/ay
ArAA7Ty
NaiENR
NOrrn-+ ROt.INA DEPARTMENT OF
EN VIP ON MENT ANQ NATURAL RESOURCES
.August 14, 2002
Subject: Speculative Limits for the Town of Highlands
NPDES Permit NC0021107
Highlands WWTP
Macon County
DearlMr. Betz:
The Town of Highlands requescDd speculative limits for an expanded discharge of 1.5 MGD to the Cullasaja
Rive. The Division of Water Quality has reviewed the request and provides the following response.
The speculative limits presented here are based on our understanding of the proposal and of present
environrnental conditions. The Division of Water Quality (DWQ) cannot guarantee that it will issue the Town an
3'PDES permit at the expanded flow rate. Nor can we guarantee that the effluent limitations and other '.
requirements included in any permit will be exactly as presented here. Final decisions on these natters will be
made only after the Division receives and evaluates a formal permit application for the Town's proposed
discharge.
Environmental Assessmertte of New Projects
Please be aware that the Town of Highlands will have to evaluate this project for environmental impacts before
receiving a modified permit. Anyone proposing co construct new or expanded waste treatment facilities using
publi}r funds or public (state) lands must first prepare an Environmental Assessment (EA) when wastewater flews
(1) equel or exceed 0.5 MGD or (2) exceed one-third of the 7Q10 flow of the receiving stream. DWQ Will not
accep'.t a permit application for a projec: requiring art environmental assessment until the Division has approve.,.l
the EA and sent a Finding of No Significant Impact (FONSI) to the stare Clearinghouse for review and cormmeet.
If an Envircnrlental Assessment is required. it should contain a. dear justification for the proposed facility. It
shoed provide an analysis of potertial alternatives, including a thorough evaluation of non -discharge
alternatives. Nondischarge alternatives or alternative-; to expansion, such as spray irrigation. water conservatii n.
inflow and iniiltratioreteduction or connection to a regional treatment and disposal system, are considered to i'e
environmentally preferable to a surface water discharge. In accordance with the North Carolina General Statuses.
the preferred alternative must be the practi_able wash, treatment and disposal alternative with the least advers.•
impact on the environment is required to be implemented. If the EA demonstrates that the project may result itl a
1(717.'ti�lail Service Center, Raleigh, North Carolina 2?6c9-16 17 Telephone [phone] FAX [phone]
Visrr OF ON THE INTERNE; r�
htt,. /1n1n onr grata n- ,.c oanni:e
An Equal Opportunity Affirmative Action Employer

9-434-202 1 1 : 26AI i FROM
P.
Sp I lative NPDES Limits
.Town of Highlands
NPOES NC0021407
sigtii�Eicant adverse effect or, the quality of the environment, you must then.Frepare an Environmental Impact
Statement. Todd Kennedy of the Water Quality Planning Branch can provide additional information regarding
the requirements of the N.C. Environmental Policy Act. You can contact Mr. Kennedy directly at [phone],
ext. 5,55.
S�De, relative L'f£lueyat Limitt
The fvirier 7Q10 flow has been updated. The winter 7Q1Q flow used during the previous permitting cycle was
based on and. an analysis of flow records from 1971 through 1983 and included the influence of the hydroelectric
ficiliy. Since the hydroelectric facility has been shutdown for sometime, the winter 7Q10 flow calculated during
the previous permitting cycle is no longer accurate. Therefore, :he United States Geological Survey (USGS)
.recal4uiated the winter 7Q10 flow and based on preliminary results, the winter 7Q10 flow has been revised to 7.45
cfs. Even though the winter 7Q10 has been updated, the flow having the greatest influence on permit limitations •
continues to be the summer 7Q10. The summer 7Q10 flow remains unchanged since the previous permitting
cy ci (confirmed by USCS). s 7. a c fs
Based on the available information, tentative iirnits for a proposed expansion of the discharge to 1.5 MGD to the
Cullasaja River are presented below.
Effluent Limits for 13 MGD
Flow • (MGD) 1.5 s 2.33 cfs
BODs - Monthly Average (mg/L) 30.0
BOD$ - Weekly Average (mg/L) 45.0
NHs-N (Summer) - Monthly Average (mg/L) 3:4
NH3-N (Summer) - Weekly Average (mg/1) See Text
NI-11-N (Winter) - Monthly Average (mg/L) 6.7
NHrN (Winter) - Weekly Average (mg/L) See Text
Total Suspended Residue - Monthly Average (mg'L) 30.0
Total Suspended Residue -Weekly Average (mg/L) 43.0
Dissolved Oxygen (rngiL) 5.0
Fecal Coliform - Monthly Average (t/100 mL) 200
Fecal Coliform - Weekly Average (tft00 rnl..) 400
pH (5.U.) 6.0 - 9.0
Total Residual Chlorine (ug/L) 22
Chronic Toxicity Pass/Fail @ 24.4% with Ceriodaphnia Dubia
Flow Limits. The flow will be limited to 1.5 MGD as requested by the consultant. This limit will be applied as a
monthly average.
BODs_ The limits for these parameters were based on the waste assimilating capacity of the receiving stream at
low flow conditions. The limitations presented here are based on the results of a one dimensional dissolved
oxygen model. Based on the results of this modeling effort, secondary treatment limits will protect North
CaroUina's instrearn dissolved oxygen standard in the Cullasaja River.
1

9-04-202 1 1 : 26Af,1 FRO 1
P. 4
Speculative NPDES Limits
Town of Highlands
NPDES NC0021407
NNIH3-N,. Ammonia was evaluated for both dissolved oxygen depletion and toxicity. The limits for ammonia are
based on protection of the instream toxicity and North Carolina's instream ammonia criteria. These speculative
limits currently contain only monthly average limits for ammonia. The Division is currently evaluating an
appropriate weekly average limit for all discharges in North Carolina. The current schedule is to complete this
evaluation by September 30. 2002. At that time, th'e Division will begin requiring both monthly and weekly
average limits for ammonia.
Total'Suspended Solids. The limits for total suspended solids are standard for secondary treatment of municipal
wastewater.
Fecal:Coliform, pH, The limits for fecal coliform bacteria and'pH are derived to protect water quality in the
receiting stream and remain the same as the existing permit. The fecal coliform limit is based on a geometric
mear{.
t
Total:Residual Chlorine (TRC). In North Carolina, waters designated as trout waters have a TRC standard. Since
the Oullasaja River is designated as trout water, a limit for total residual chlorine is included for protection of the
TRC -tandard.
Chronic Tonicity Testing. Chronic pass/fail toxicity testing at 24.4% with Ceriodaphnia Dubnia will be required
in the NPDES permit for a wasteflow of 1.5 MGD. Quarterly monitoring will be required. The Division of Water
Quality requires toxicity testing for major discharges. Since major is defined as greater than or equai to 1 MGD of
Nast' flow, at the expanded flow the facility will be•considered a major discharger and a toxicity limit is required.
Dissolved Oxygen. Limits for dissolved oxygen are based on protection of North Carolina's standard.
Nutrients: Total Phosphorus, Total Nitrogen. No limits for nutrients are recommended at this time. However, if
future instream assessments indicate that the accumulation of nutrients are creating eutrophication problems,
nutrient limits may be added to the permit. •
The Division of Water Quality will perform a ctznplete evaluation of limits and monitoring requirements for
metals and other toxicants when we review the Town's formal permit application.
I trust this response offers sufficient guidance for the County's proposed treatment plant. If you have any
addi "onal questions about these limits, feel free to contact Michael Myers at [phone], extension 508.
Sincerely,
David A. Goodrich
Supervisor, NPDES Unit
cc: Asheville Regional Office - Division of Water Quality
CaIlie Dobson - Division of Water Quality, Planning Branch
Todd Kennedy (Division of Water Quality, Planning Branch
Central Files
NPDES Unit Files

/•
APPENDIX E.
EA Review Comments and Responses

1N A TF Michael F. Easley, Governor
William G. Ross Jr., Secretary
`O. QG North Carolina Department of Environment and Natural Resources
Uj r Alan W. Klimek, P.E. Director
Division of Water Quality
C) "c
July 15, 2002
Mr. H. Ward Marotti
Robert J. Goldstein & Associates, Inc.
8480 Garvey Drive
Raleigh, NC 27616
Subject: Completeness Review for Highlands WWTP EA - May 2002
DWQ# 13128
Dear Mr. Marotti:
Comp1eft1ieSs keuiew
Thdd kewKeity
The Division of Water Quality (Division) has concluded a completeness review of the subject document.
Please revise the EA to address the issues identified below. Next, submit ten copies to me for internal
review by the Department of Environment and Natural Resources (DENR). Issues identified during.
DENR review will need to be resolved prior to State Clearinghouse circulation.
1. Section 3.4: In the fifth paragraph, remove the speculative phrase, "...because regionalization would
face political opposition."
2. Section 4.5: This section indicates that the State Historic Preservation Office (SHPO) had no
comment during scoping. Does this mean there are no archaeological and historic resources in the
area? This should be confirmed prior to DENR review. If necessary, contact SHPO directly to
complete this section.
3. Sections 4.10.2 - 4.11.6: The various forest descriptions are not necessary. If desired, include. these.
descriptions in an appendix. . :
4. Sections 4.13.1 - 4.13.50 and 5.13.1- 5.13.50: Summarize this information into a more concise form '
such as a table. If desired, the detailed species descriptions can be attached as an appendix .but: should;
not be included in the main body of the document. •
5. As acknowledged in the EA, secondary and cumulative impacts associated with growth and' . -
development may result from this project, including increased urban runoff. Throughout the.
document, mitigation of these land use impacts is purportedly achieved through enforcement of the .
zoning and subdivision ordinances as well as existing state programs. In the event that existing state
and local programs do not provide adequate mitigation, additional local protection may need to be
considered. Emphasis should be placed on.actual implementation of mitigation measures.
Maintaining preclevelopment hydrologic functions is an important goal in watershed development.
Planning design that reduces the creation of impervious area, provides for perviout green
infrastructure, and maintains natural detention and retention functions should be encouraged.
Disconnecting impervious surfaces, connecting pervious surfaces, and routing flow through vegetated
conveyances can reduce impacts. When development in a watershed or subwatershed exceeds 10% to
15% impervious surface coverage, streams and the hydrologic regime are negatively impacted. At •
increasing levels of imperviousness, it becomes especially important to implement appropriate
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
Stia
RUDENR
Customer Service
1 800 623-7748

Highlands WWTP
Page 2
stormwater control to reduce pollution, maintain groundwater recharge and minimize stream channel
erosion.
Stormwater controls should protect against stream damage due to increases in volume, velocity and
peak rates of stormwater. While controls based on large storm events (e.g., 10-yr and 25-yr) may
provide overbank flood protection and safely pass larger storm events, they fail to protect water
quality and stream integrity. Smaller, more frequent storms are responsible for the majority of
channel erosion in streams. And as imperviousness in the watershed increases, the frequency of
these bankfull and mid-bankfull flows typically increases in response. For stream channel protection,
design criteria should mimic the pre -development sediment transport characteristics of the stream.
The typical two-year peak discharge control (to predevelopment levels) is often insufficient for
channel protection: it does not properly address increases in detention -associated flow duration and
development -associated peak runoff frequency. Extended detention of the one-year, 24-hour storm
event will likely be needed to adequately protect channels. Equivalent control measures may also be
considered. In addition, appropriate treatment of stormwater for water quality protection should be
implemented.
Provide a discussion on how stream channels will be protected from development impacts. The upper
Cullasaja River and Mill Creek are rated impaired by the Division due to a number of development=.:
related impacts including stormwater. Protection will be needed to prevent further degradation;to: • :
these and other streams in the service area. Reliance on the water supply watershed protection
ordinances, which are limited in scope, will likely not be sufficient.
6. Comprehensive protection of streams requires adequate buffer widths to maintain the multiple: aquatic
ecosystem functions provided by riparian areas. Minimum buffer widths of 50 feet for intermittent
streams and 100 feet for perennial streams are recommended. A significant portion of the buffer
adjacent to the streambank should be undisturbed, natural vegetation. Alternative measures suitable
for this area may be considered given they provide a similar level of protection. Additional buffer
protection should be considered by the Town.
In addition, since streams function as a continuum, the absence of protected riparian buffer along
certain reaches will make it difficult, if not impossible, to avoid negative impacts in adjacent and,
downstream reaches. Identify unprotected areas, indicate why they are not protected, and describe
how impacts to these particular stream reaches will be avoided? Local protection may need . to be
considered.
7. Other comments:
• The mailing address of the State Project Agency is 1617 Mail Service Center, Raleigh 27699-
1617. The lead agency contact is J. Todd Kennedy.
• Page IV: The caption for Figure 2 indicates Wake County.
• Review and edit- the document for proper punctuation (e.g., double periods•throughout the
document).
• Section 7.0: An NPDES permit will also be required for this project.
• Include a copy of the speculative limits letter from the Division as an attachment.•
• Include this letter and all future agency correspondence in the attachments section.

Highlands WWTP
Page 3
Feel free to contact me at 919.733.5083 x555 if you need any further assistance. Thank you.
Sincerely,
9, - - - - 2.
J. Todd Kennedy
SEPA Coordinator

PENT Revi&
ern
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Govemor William G. Ross Jr., Secretary
MEMORANDUM
TO:
FROM:
Todd Kennedy
Division of Water Quality
Melba McGee le
Environmental Review Coordinator
RE: #1204 EA for Town of Highlands WWTP, Macon County
DATE: September 26, 2002
The referenced project has been circulated among our internal
divisions.
The attached comments should be addressed before this project moves
forward. After you have satisfied the issues raised, please provide me.
with a memorandum verifying that agency concerns have been adequately
addressed. If substantive changes are made in the environmental
assessment, I recommend the revised document be circulated again through
our internal review process for final approval. Either way, agency
comments will need to be addressed and incorporated into the
environmental assessment prior to the State Clearinghouse review.
Thank you for the opportunity to respond.
Attachments
1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: [phone] \ FAX: [phone] Internet: www.enr.state.nc.us/ENR/

Michael F. Easley. Governor
nF 1N Q rF� i William G. Ross Jr.. Secretary
�� North Carolina Department of Environment and Natural Resources
r Alan W. Klimek, P.E. Director
Division of Water Quality
rods k- viedy
October 9, 2002
Mr. Gerald B. Pottern
Robert J. Goldstein & Associates, Inc.
8480 Garvey Drive
Raleigh, NC 27616
Subject: DENR Review for Highlands WWTP EA - August 26, 2002
DWQ# 13128
Dear Mr. Pottern:
The Water Quality Section in the Division of Water Quality (Division), other agencies within the
Department of Environment and Natural Resources (DENR), and the NC Wildlife Resources Commission
(WRC) have completed a review of the subject document. Significant concerns were raised during this
review. We agree with WRC's position that the ordinances presented do not provide adequate mitigation
for secondary and cumulative impacts. Please address the issues below in a revised EA.
Impaired Streams
The upper Cullasaja River and Mill Creek are rated impaired by the Division due to a number of
development -related impacts including stormwater. The Division will soon release a report entitled,
Assessment Report: Biological Impairment in the Upper Cullasaja River Watershed, presenting the
causes, sources and potential remedies for watershed impairment.
Besides toxicants and the impacts of in -stream impoundments, one of the causes of impairment to Mill
Creek is scour from urban stormflows. Such degradation from past development should highlight the
need for enhanced protection measures to reduce impacts from future development. In addition, the
assessment reveals that existing protections, including the :DVS -HI Tr classifications of both the Cullasaja
River and Mill Creek, are not adequately protecting water quality. How will the Town prevent further
degradation to these and other streams in the service area covered by this WWTP expansion?
Stormwater
We commend the Town for adopting provisions in its subdivision ordinance that permit the construction
of clustered developments. Often, these developments have a decreased impact on the surrounding
environment. However, other than this provision, there are few requirements that appear to provide
protection to water resources and aquatic habitat. We recommend the Town consider adopting
stormwater control requirements for protection of stream channels and reduction of runoff pollution.
Additional development designs that reduce the creation of impervious area, provide for pervious green
infrastructure, and maintain natural detention and retention functions should be encouraged.
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
Customer Service
1 800 623-7748

Highlands WWTP
Page 2
Stormwater runoff generated by development should be treated to decrease pollutant loading into nearby
water bodies. Furthermore, stormwater controls should also protect against stream damage due to
increases in volume, velocity and peak rates of stormwater. This is particularly important for catchements
with greater than 10 to 15% impervious surface coverage.
Extended detention of the one-year, 24-hour storm event should be considered to adequately protect
stream channels. Alternative control measures may be appropriate for this area given that they reduce the
frequency, magnitude and duration of post -development bankfull flow conditions and protect downstream
channels from scour and erosion. Note that controls based solely on large storm events (e.g., 10-yr and
25-yr) may address overbank flood protection but generally fail to protect water quality and stream
integrity.
Stream Buffers
We commend the Town on requiring undisturbed buffers in water supply watersheds. We have
understood this to mean that a naturally vegetated buffer is protected. If this is not the case, please
clarify. Also indicate the percentage of the service area that is protected by the water supply buffers.
As mentioned in a previous letter, since streams function as a continuum, the absence of a protected
riparian buffer along certain reaches will make it difficult to avoid negative impacts in adjacent and
downstream reaches. As part of the mitigation for this project, we recommend that buffer protection be
extended to all perennial and intermittent streams throughout the service area. A significant portion of the
buffer adjacent to streambanks should be undisturbed, natural vegetation. It is important to note that the
25-foot buffer required for trout streams (Tr) in the service area is often inadequate for protection of
streams from the full array of secondary impacts.
Other Comments
• Provide responses and revisions to the document, where appropriate, for the attached comments from
WRC and the Division's NPDES Unit.
• Page numbers were missing from much of the document.
• Section 1.0: Delete the second paragraph.
• Section 5.8: Delete the second sentence of the second paragraph.
As highlighted above, additional local protection should be considered to support a Finding of No
Significant Impact (FONSI). The Town may wish to consider a local resolution indicating a commitment,
implementation plan, and time frame for adopting additional protection measures for impacts from new
development accommodated by this WWTP expansion.

Highlands WWTP
Page 3
We recommend that you contact WRC directly regarding their comments. Once revisions have been
completed, submit one copy to the Division and another to WRC for review. Feel free to contact me at
919.733.5083 x555 if you need any further assistance. Thank you.
Sincerely,
•'/S
J. Todd Kennedy
NC Environmental Policy Act Coordinator
Attachments
CC: Owen F. Anderson, WRC w/o attachments

r. Rodnyu ez
NC Division of Water Quality
NPDES Unit
MEMORANDUM
To: Todd Kennedy
•
Throu9 h: Dave Goodrich
From: Teresa Rodriguez 1ti-
Date: October 1, 2002
Subject: Town of Highlands EA
The Town of Highlands submitted an Environmental Assessment for the
expansion of the Wastewater Treatment Plant from 0.5 MGD to 1.5 MGD. We
commend the Town for initiating public participation early in the process by
holding a public meeting to explain the proposed expansion. The following
comments are offered regarding the Environmental Assessment document:
♦ Growth rates of 1.79 and 3.93 for the residential and seasonal population
were used for the flow estimate. Provide the source or reference for the
growth rates used in the flow projections for both the permanent residents
and the seasonal residents.
• The areas to be annexed include existing developments. Describe the
methods of wastewater disposal for the existing developments and any
existing discharge permits. Have these developments given the town any
letter of intent to connect? Please provide a discussion of the level of
commitments from the areas to be annexed.
♦ The town will extend sewer service to areas served by on -site treatment
systems. Describe the operational conditions or known problems (if any)
of the existing on -site treatment systems.
• Evaluate the alternative of reusing wastewater in existing or proposed golf
courses as part of the Engineering Alternatives Analysis.

NCli1RC
Fax
Sep 26 '02 10:30
P. 03 Q. 4Hderse6
North Carolina Wildlife Resources Commission
Charles R. FuIlwood, Executive Director
MEMORANDUM
TO; Melba McGee, Environmental Coordinator
Office of Legislative�a d Inyertment airs
•
FROM: Owen P. Anderson, ntair Region Coordinator
Habitat Conservation Program
DATE: September 26, 2002
SUBJECT: Environmental Assessment for Town of Highlands WWTP, Macon County, North
Carolina, DENR No. 1204
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.G. 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 Town of Highlands proposes to expand the wastewater treatment plant to serve the
Town of Highlands and five annexation areas. The expansion will triple treatment capacity from
0.5 to 1,5 million gallons per day. There is no reference to expansion of the collection systems;
however, the scoping letter refers to an annexation area.
There are significant aquatic and terrestrial resources within the affected area of this
project. Most of the affected area appears to be in the Cullasaja River watershed but some
impacts may occur within the Chattooga River drainage. Both of these streams support
significant aquatic resources. in the Highlands area, many of the streams within these two basins
are either classified by the Division of Water Quality as trout waters or are designated trout
waters by the NCWRC. Additionally, Big Creek, Lake Sequoyah and a portion of Mirror Lake
are classified as WS-III tr HOW. Additionally, the streams in the area provide significant
recreational opportunities.
The North Carolina Natural Heritage Program identifies a number of natural heritage
elements for the Highlands area. These elements are both on public and private lands and
include plants, animals and Community types. For example, there is a Southern Appalachian bog
near one annexation area and a record for a bog turtle (C'lemrnys mulenbergii) in the vicinity of
this annexation area but in a different location than the bog. Bogs provide important habitat for
fish
dv and wildlife a federallyhe State threateneds species,ly threatened we request that h proe. ject t1nce this sponsors project
their could
adversely impactY
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center - Raleigh, NC 27699-1721
Telephone: [phone] ext. 2R 1 • Fax: [phone]

NCWRC Fax Sep 26 '02 10:30 P.04
Town of Highlands WWTP 2
Macon County, Cullasaja & Chattooga Rivers
September 26, 2002
consultants consult early in the project with the U.S. Fish and Wildlife Service. The Service can
be contacted in Asheville at [phone].
The environmental assessment was well written and did a good job of describing the
project. We agree that there should be little direct impact from the construction of the new
wastewater treatment plant. The site was graded in 1994; thus, we believe that habitat values At
this site are limited. •
There should be some benefits from the expansion of the wastewater treatment plant so
effluent quality should improve. If pollutant concentrations are reduced through the new permit .
and chlorine is eliminated, aquatic life downstream of the discharge should benefit. However,
adverse secondary and cumulative impacts could more than off` set these benefits.
The EA points out the significance of the Highlands area. We certainly agree with the
statement, "The Highlands area is geologically, topographically and ecologically unique, even
within the context of the regionally unique southern Appalachian Mountains." The EA points
out that much of the service area contains suitable habitat for many rare species that are known
from the Highlands area, The new infrastructure will provide a stimulus for new development
that will result in increased land clearing, increased impervious surfaces, increased urban runoff
and unregulated construction in streams and riparian zones. Wildlife may be impacted from
secondary and cumulative impacts from the land clearing, sewer construction, and fragmentation
of habitat. Species that could be impacted include rare plants and animals and community types.
Several streams, Mill Creek and Cullasaja River, are notsupporting their intended uses.
These streams are listed on the 303(d) list. Biological recovery in Mill Creek is considered to be
problematic due to golf courses and urban development. We are concerned that additional
development resulting from WWTP expansion will only exacerbate the problems with these and
threaten additional streams within the Highlands area,
The EA includes some information on ordinances; however, given the significance of the
Highlands area, we do not believe that these ordinances provide nearly enough protection to
mitigate for the sipilcant secondary and cumulative impacts that can result from growth and
development facilitated by the infrastructure expansion.
We are unable to concur with this project due to a lack of adecjuate mitigative measures
to address the potential secondary and cumulative impacts to the significant fish and wildlife
resources and respective habitats. Information needs to be provided on the following specific
items before we can complete review of this project.
1. Although the EA identified a resource, the Highlands Land Trust, that is available to assist
the town and landowners in developing protection strategies for ecologically sensitive lands,
including rare species, we did not find in commitment to such a plan. Given the habitat
values and known records of rare species, the new service areas need to be thoroughly
surveyed and protection strategies developed and implemented based on these surveys prior
to expanding the infrastructure.
2. Several streams in the Highlands area 'tie on the 303(d)-priority list. Local initiatives and
ordinances could help address this situation, What initiatives or ordinances are in place to
assist with the restoration of these streams and protection of wetland areas? Since golf
courses are a major factor in this impairment, special attention and work needs to be done on
the golf courses to reduce pollutants and establish forested riparian buffers where needed,
Restoration of forested riparian buffers, greenways and stormwater management are
especially relevant to the overall discussion.

NCWRC Fax Sep 26 '02 10:31 P.05
Town of Highlands WWTP 3 September 26, 2002
Macon County, Cullasaja & Chattooga Rivers
3. Sewer line extensions should be included in this assessment since the WWTP
is pri
ily
being expanded to serve new areas. Fragmenting projects makes assessmenttimpacts
and determining measures to mitigate those impacts difficult.
4. We request that the WWTP be equipped with emergency generators to provide power Q all
essential treatmenf=works during a power outage. We do not consider dual,feed power
supplies to be an adequate emergency power source.
5. Althoughthe pond -draining ordinance is a good idea, the turbidity standard
trout
man ohe streams in the Highlands area are trout streams. The State ntuond-
standard for
waters is 10 ntu and for lakes is 25 ntu. Please provide clarification of wh the y p
draining ordinance is set at 50 ntu rather than 10.
G. Wh
at ordinances and initiatives are in place to address stormwater runoff from residential
development and individual commercial structures? Given that Hipp 1 nd i s primarily s wales,
p,grassed residential community, stormwater management measures
(e.g., usinesses mould provide
sheet flow and pervious pavement) for individual residences
cumulative water quality benefits and protect area streams from scouring.
In addition to providing the.preceding information, the NCWRC requests that the of the Town
of Highlands implement the following guidelines to mitigate the secondary imp
actsproposed project on fish and wildlife resources.
1.
We recommend the maintenance or establishment of a minimum 100-foot native
forested
buffer along each side of perennial streams and 50-foot native forested
buffer
service eeach
side of intermittent streams and wetlands throughout the present and
or the entire municipal jurisdiction (EPA 2000; Stewart et al. 2000). We additionally
encourage the implementation of buffers on ephemeral streams due ot he Peteportant et al.
functions that they provide as headwater streams (Alexander et a ,
2001). Buffers should be measured horizontally from the cdge ofthe stream bank
Knutson and Naef 1997), which may result in wider buffers on higher
gradients,
dea n s,� der,
must be provided over the entire length of stream, including headwaterwould include
recommend leaving30% of the development area as greenspace, which
we is connected to natural resources.
buffers and wetlands and ensure that the greenspace
Wide, contiguous riparian buffers have greater and more flexible potential than
maintainr
biological integrity (Horner et al, 1999) and could amelioratemany
options to g �'
ecological issues related to land use and environmental quality (Naiman et
habitat ain change,93). As
ex ansion of developed areas continues into the watershed, wildlife v 1 corridor
become fragmented, and even disappear. Riparian buffers
additionidriparian tbuffers serve to
habitat areas for wildlife displaced by development.
protect water quality by stabilizing stream banks, filtering capacity of stormwater runoff,
and provide habitat for aquatic and fisheries resources. of
2. We recommend that sewer lines, water lines, and other utility infrastructure be kept out
riparian buffer areas (Knutson and Naef 1997; and references therein). All utility
crossings should be kept to a minimum, which includes careful routingesithere ts not the
combination of utility crossings into the same right-of-way fipnctionesdis ro disproportionate to
issue), piscontiguous buffer segments can impair riparian Horner 2000; Van Sickle
the relative occurrence of the breaks in the Cumular tive impacts. The directional bore
2000), and multiple crossings can result
Installation of utilities beneath the riverbed, avoiding impacts to the stream and buffer)
stream crossing method should be used for utility crossings wherever practicable,
the
open cut stream crossing method should only be used when water
level is lowed and
nwstream
flow is minimal. Manholes or similar access structures should not

NCWRC Fax:[phone] Sep 26 '02 10:32 P.06
Town of Highlands WWTP 4
Macon County, Cullasaja & Chattooga Rivers
September 26, 2002
buffer areas. Stream crossings should be near perpendicular (75° to 105°) to stream flow
and should be monitored at least every three months for maintenance needs during the
first 24 months of the project and then annually thereafter. Sewer lines associated with
crossing areas should be maintained and operated at all times to prevent the discharge to
land or surface waters. We recommend a minimum 50-100-foot setback on all streams,
sakes, and wetlands for these structures, which falls in line with the recommended buffer
widths. In circumstances where minimum setbacks cannot be attained, sewer lines shall
be constructed of ductile iron or other substance of equal durability. Further, pesticides
(including insecticides and herbicides) should not be used for maintenance of rights -of -
way within 100 feet of perennial streams and 50 feet of intermittent streams, or within
floodplains and wetlands associated with these streams.
3. Avoid the removal of large trees at the edges of construction corridors. Re -seed
disturbed areas with seed mixtures that are beneficial to wildlife. Avoid fescue -based
mixtures because fescue is invasive and provides little benefit to wildlife. Native, annual
small grains appropriate for the season are preferred and recommended (See
http://www.l e . tattlic uslwet, lantlwetland_plants.htt and
http:/lwww.co.mecklenburg.nc.us/coenglStotm/services/ve1tionlveaetation.htm .
to establish brushpiles
Where feasible, use woody debris and logs from corridor clearing
and downed logs adjacent to the cleared right-of-way to improve habitat for wildlife-
Allowing the corridor area to revegetate into a brush/scrub habitat would maximize
benefits to wildlife. For areas adjacent to residential areas, a native shrub/grass option
may also be beneficial. Minimize corridor maintenance and prohibit mowing between
April 1 and October 1 to minimize impacts to nesting wildlife. We suggest a
maintenance schedule that incorporates only a portion of the area —one third of the area,
for example —each year instead of the entire project every 3 or 4 years. Herbicides and
pesticides should never be used in wetland areas or near streams, as described above in
item 3:
4. We recommend that the local governments prohibit commercial or residential
development within the 100-year floodplain. Undeveloped floodplains strongly influence
aquatic systems, support a combination of riparian and upland vegetation used by aquatic
communities (Junk et al.
rich source of food to
and terrestrial wildlife, supply aaquatic
1989), and provide an important sediment trapping function (Palik et al. 2000). The
filling of floodplains increases the potential for flooding of adjacent properties and
interferes with the natural hydrologic process of the waterways. It also disrupts the
continuity of migration corridors for wildlife. Instead, we recommend that developers set
aside a portion of the land to be developed as green space and concentrate these areas
along the streams and rivers (see Item 1 above). In addition we encourage "infill" (new
development in unused or underutilized land in existing urban areas) development in
urbanized portions of the jurisdiction and recommend the site practices for infill and
brownfield development issued by the U. S. Environmental Protection Agency (EPA)
Ottp://www.epa.gQv; accessed May 2002) and the Center for Watershed Protection
(http;/twww.cwp.org/; accessed May 2002). Floodplain maps may need to be updated to
reflect development of the watershed. Floodplain remapping studies in Charlotte showed
that buildout conditions would result in a floodplain width change from an average of 429
feet to 611 feet (http://www.co:mklenburg nc. n storm/floo s.httn;
accessed May 2002)
5 We recommend that the local government limit impervious surfaces to less than 10% of
the watershed (Schueler 1994; Arnold and Gibbons 1996; Doll et al. 2000; Mallin et al.
2000; May and Horner 2000; Stewart et al. 2000; Paul and Meyer 2001). The
construction of roadways and other impervious surfaces in new neighborhoods can
produce short-term direct impacts as well as long-term cumulative effects. Multiple
studies have shown that stream degradation occurs at approximately 10% coverage by

NCWRC
Fax:[phone] Sep 26 '02 10:33 P.07
Town of Highlands WWTP 5
Macon County, Cullasaja & Chattooga Rivers
September 26, 2002
impervious surfaces (Schueler 1994; Arnold and Gibbons 1996; Doll et al. 2000; Mallin
et al. 2000; May and Horner 2000; Stewart et al. 2000; Paul and Meyer 2001). Likewise,
the Wake County Watershed Management Plan Task Force performed a correlation
analysis of impervious surfaces to watershed classification based on water quality data,
and they found that watersheds of unimpaired streams averaged 8% imperviousness,
impacted streams averaged 11%, and degraded streams averaged 24%
(http;//projects.ch2m.com/Wak.ecountyl; accessed May 2002).
We also recommend that the local goverrunent provide for sufficient open space to
effectivelyreduce impervious surface so that predevelopnment hydrographic conditions
are maintained, limit curb and gutter in new'developments, and prevent direct discharges
of stormwater into streams. To achieve no net change in the hydrology of the watershed,
we recommend installation of grassed swales in place of curb and gutter and on -site
stormwater management (i.e. bioretention areas or other attenuation measures). These
designs often cost less to install (Kwon 2000) and significantly reduce environmental
impacts from residential development. Information regarding financing stormwater
management can be found at Inv :llstormwaterriance.urbancenter.i iWedu/ (accessed
May 2002).
Many of these recommendations have been applied in Maryland to protect the
Chesapeake Bay from water quality degradation (MDE 2000). Suggested examples to
accomplish the <10% impervious goal are using conventional designs at a level of <10%
imperviousness or using conservation clusters with higher densities, with dedicated open
space and other stormwater control measures to mimic the hydrograph consistent with an
impervious coverage of less than 10%. Reduction of road widths is one method to reduce
overall impervious surface coverage. The N. C. Department of Transportation (NCDOT)
has issued road guidelines that allow for the reduction in street widths when compared to
standard secondary road guidelines. This material can be found at In addition,
dPh,dot statemc,us/o rations/tnd.pdf. (accessed May 2002).
there are site planning practices that, when incorporated with the above mentioned road
building guideline, can further reduce the amount of impervious surface within a site (see
recom
mendations in the document Better Site Design (Center for Watershed Protection;
http:llwww.cwp.org/; accessed May 2002).
6. Use bridges for all permanent roadway crossings of streams and associated wetlands to
eliminate the need to fill and culvert, where practicable. If culverts must be used, the
culvert should be designed to allow passage of aquatic organisms. Generally, this means
that the culvert or pipe invert is buried at least one foot below the natural streambed. If
multiple cells are required, the second and/or third cells should be placed so that their
bottoms are at stream bankfull stage. This will allow sufficient water depth in the culvert
or pipe during normal flows to accommodate movements of aquatic organisms. If
culverts are long and sufficient slope exists, baffle systems are recommended to trap
gravel and provide resting areas for fish and other aquatic organisms. If multiple pipes or
cells are used, at least one pipe or box should be designed to remain dry during normal
flows to allow for wildlife passage. In addition, culverts or pipes should be situated so
q P �
that no channel realignment or widening is required. Widening of the stream channel at
the inlet or outlet of structures usually causes a decrease in water velocity causing
sediment deposition that will require future maintenance. Finally, riprap should not be
placed on the streambed.
7. We recommend that municipalities incorporate the elements listed below into their
erosion and sediment control plans (see Brown and Caraco 2000 for additional
information). Sediment is considered the most important cause of water pollution in the
United States (Waters 1995), and construction is considered the most damaging phase of
the development cycle to aquatic resources (Brown and Caraco 2000).

NCWRC Fax:[phone] Sep 26 '02 10:34 P.08
Town of Highlands WWTP 6 September 26, 2002
Macon County, Cullasaja & Chattooga Rivers
a) Minimize clearing and grading and only perform these operations in the context of an
overall stream protection strategy. and stabilize
b) Protect waterways by preventing clearing adjacent to waterways,
drainage ways. c) Phase construction for larger construction sites (325 acres) to reduce the time and
area that disturbed soils are exposed.
d) Stabilize soils as rapidly as possible (<2 weeks) by establishing a grass or Mulch
cover.
e) Protect steep slopes, and avoid clearing or grading existing steep slopes as much as
possible.
f) Establish appropriate perimeter controls at the edge of construction sites to retain or
filter concentrated runoff from relatively short distances before it leaves the site.
g) Employ advanced settling devices that contain design features which include greater
wet or dry storage volume, perforated risers, better internal geometry, use of baffles,
skimmers and other outlet devices, gentler side -slopes, and multiple cell construction.
h) Implement a certified contractors program so that trained and experienced contractors
are on -site.
i) Sedimentation impacts should be minimized by regular inspection of erosion control
measures, and sediment control devices should be maintained in good and effective
condition at all times, Erosion and sediment controls should be reassessed after
storms. The incorrect installation of erosion control structures and those not properly
maintained can result in sedimentation impacts to nearby streams and wetlands.
Thank you for the opportunity to provide input into this project review. If you need
these comments, please contact me at 828-452-2546 ext 24.
further information on
cc: Brian Cole, Supervising Biologist, USFWS
J. Todd Kennedy, Environmental Coordinator, DWQ
Steve Hall, Zoologist, NC Natural Heritage Program
References:
Alexander, R. B., R. A. Smith, and G. E: Schwarz. 2000. Effect of stream channel size on the
delivery of nitrogen to the Gulf of Mexico. Nature 403 :758-761.
Arnold, C. L., and C. J. Gibbons. 1996. Impervious surface coverage —the emergence of a key
environmental indicator. Journal of the American Planning Association 62:243-258.
Brown, W., and D. Caraco. 2000. Muddy water in - muddy water out? Watershed Protection
Techniques 2(3):393-403.
Doll B. A. D. E. Wise -Frederick, C. M. Buckner, S. D. Wilkerson, W. A. Harman, and R. E.
Smith. 2000. Hydraulic geometry relationships for urban streams throughout the
piedmont of North Carolina. Pages 299-304 in P.J. Wigington, Jr. and R.L. Beschta, eds.
Proceedings of the American Water Resources Association International Conference on
riparian ecology and management in multi -land use watersheds, Portland, Oregon.
SPA (U. S. Environmental Protection Agency). 2000. Model ordinances to protect local
resources. EPA, Office of Water, Washington, D. C. Available;
inizi!w_w_.w,sa;goy/_owowwtrlllsIPS/Ardinancg/ d.o. ..m. (May 2002).
Horner, R. R., C. W. May, E. H. Livingston, and J.Maxted. 1999. Impervious cover, aquatic
community health, and stormwater BMPs: is there a relationship? Proceedings of the
Sixth Biennial Stormwater Research Conference; Tampa, Florida.

NCWRC
Fax:[phone] Sep 26 '02 10:34 P.09
Town of Highlands WWTP 7
Macon County, Cullasaja & Chattooga Rivers
September 26, 2002
Junk, W. J., P. B. Bayley, and R: E. Sparks. 1989. The flood pulse concept in river-floodplain
systems. Pages 110-127 in D. P. Dodge, ed. Proceedings of the International Large
River Symposium. Canadian Special Publication of Fisheries and Aquatic Sciences 106,
Ottawa.
Knutson, K. L., and V. L. Naef. 1997. Management recommendations for Washington's priority
habitaits: riparian. Washington Department of Fish and WildIife, Olympia.
Kwon, H. 2000. An introduction to better site design. Watershed Protection Techniques
3(2)623-632.
Mallin, M. A., K. E. Williams E. C. Esham, and R. P. Lowe. 2000. Effect of human
development on bacteriological water quality in coastal watersheds. Ecological
Applications 10:1047-1056.
May, C. W., and R. R. Horner. 2000. The cumulative impacts of watershed urbanization on
stream -riparian ecosystems. -ri arian Pages 2S1-286 in P. J. Wigington, Jr. and R. L. Beschta,
g
eds. Proceedings of the American Water Resources Association International Conference
on riparian ecology and management in multi -land use watersheds, Portland, Oregon.
NCDEHNR. 1994. Tar -Pamlico River Basinwide Water Quality Management Plan. North
Carolina Department of Environment, Health, and Natural Resources, Division of
Environmental Management, Water Quality Section.
MDE (Maryland Department of the Environment). 2000. 2000 Maryland stornwater design
manual, volumes I and U. Center for Watershed Protection and MDE, Water
Management Administration, Baltimore, Maryland. Available:
http://mww,� .mde.state.m . a en ironment/wmalstotmwatetmanuali. (May 2002).
Naiman, R. J., H. Decamps, and M. Pollock. 1993. The role of riparian corridors in maintaining
regional biodiversity. Ecological Applications. 3:209-212.
Palik, B. J., J. C. Zasada, and C. W. Hedman. 2000. Ecological principles for riparian
silviculture. Pages 233-254 in E. S. Verry, J. W. Hornbeck, and C. A. Dolloff, eds.
Riparian management in forests of the continental eastern United States. Lewis
Publishers, Boca Raton, Florida.
Paul, M. J., and J. L. Meyer. 2001. Streams in the urban landscape. Annual Review of Ecology
and Systematics 32:333-365.
Peterson:, B. J., W. M. Wollheim, P. J. Mulholland, J. R. Webster, J. L. Meyer, J. L. Tank, E.
Marti, W. B. Bowden, H. M. Valett, A. E. Hershey, W. H. McDowell, W. K. Dodds, S.
K. Hamilton, S. Gregory, and D. D. Morrall. 2001. Control of nitrogen export from
watersheds by headwater streams. Science 292:86-90.
Schueler, T. 1994. The importance of imperviousness. Watershed Protection Techniques.
1(3):100-111.
Stewart, J. S., D. M. Downes, L.Wang, J. A. Wierl, and R. Bannerman. 2000. Influences of
riparian corridors on aquatic biota in agricultural watersheds. Pages 209-214 in P. J.
Wigington, Jr. and R. L. Beschta, eds. Proceedings.of the American Water Resources
Association International Conference on riparian ecology and management in multi -land
use watersheds, Portland, Oregon.
Van Sickle, J. 2000. Modeling variable -width riparian buffers, with an application to woody
debris recruitment. Pages 107-112 in P. J. Wigington, Jr. and R. L. Beschta, eds.
Proceedings of the American Water Resources Association International Conference on
riparian ecology and management in multi -land use watersheds, Portland, Oregon.
Waters, T. F. 1995. Sediment in streams: sources, biological effects, and control. American
Fisheries Society Monograph 7, Bethesda, Maryland.

Age5
State of North Carolina
NCUIeN i Department of Environment and Natural Resources Project Number: IA 0(1 Due Date: i%gi
AZo
Reviewing Office:
INTERGOVERNMENTAL REVIEW — PROJECT COMMENTS
After review of this project it has been determined that the DENR permit(s) and/or approvals indicated may need to be obtained in order for this project
to comply with North Carolina Law. Questions regarding these permits should be addressed to the Regional office indicated on the reverse of this form.
All applications, information and guidelines relative to these plans and permits are available from the same Regional Office.
PERMITS
SPECIAL APPLICAT10N PROCEDURES or REQUIREMENTS
Normal Process Time
(Statutory Time Limit),
lcp.
Permit to construct & operate wastewater treatment
facilities, sewer system extensions & sewer systems
not discharging into state surface waters.
.
Application 90 days before begin construction or award of construction
contracts. On -site inspection. Post -application technical conference usual.
30 days
(90 days)
EANPDES-permit
to discharge into surface water and/or
permit to operate and construct wastewater facilities
discharging into state surface waters.
Application 180 days before begin activity. On -site inspection preapplication
conference usual. Additionally, obtain permit to construct wastewater treatment
facility -granted after NPDES. Reply time, 30 days after receipt of plans or issue
of NPDES permit -whichever is later.
,
90 -120 days
(N/A)
0
Water Use Permit
Preapplication technical conference usually necessary
30 days
(N/A)
ID
Well Construction Permit
. Complete application must be received and permit issued prior to the
installation of a well. _
7 days
(15 days)
Dredge and Fill Permit
Application copy must be served on each adjacent riparian property owner.
On -site inspection. Preapplication conference usual. Filling may require Easement
to Fill from N.C. Department of Administration and Federal Dredge and Fill Permit.
55 days
(90 days)
Permit to construct & operate Air Pollution Abatement
facilities and/or Emission Sources as per 15 A NCAC
(2Q.0100, 2Q.0300, 2 H.0600)
N/A
60 days
Any open burning associated with subject proposal
must be in compliance with 15 A NCAC 2D.1900
N/A
60 days
(90 days)
El
Demolition or renovations of structures containing
asbestos material must be in compliance with
15 A NCAC 2D.1110 (a) (1) which requires notification
and removal prior to demolition. Contact Asbestos
Control Group 919-733-0820.
-0
Complex Source Permit required under 15 A NCAC
2D. 00
j.
e Sedimentation Pollution Control Act of 1973 must be properly addressed for any land disturbing activity. An erosion & sedimentation
control plan will be required if one or more acres to be disturbed. Plan filed with proper Regional Office (Land Quality Section) at least 30
days before beginning activity. A fee of 540 for the first acre or any part of an acre.
20 days
(30 days)
0
The Sedimentation Pollution Control Act of 1973 must be addressed with respect to the referenced Local Ordinance.
30 days
El
Mining Permit
On -site inspection usual. Surety bond filed with DENR. Bond amount varies with
type mine and number of acres of affected land. Any are mined greater than
one acre must be permitted. The appropriate bond must be received before
the permit can be issued.
30 days
(60 days)
North Carolina Burning permit
On -site inspection by N.C. Division of Forest Resources if permit exceeds 4 days
1 day
(N/A)
0
Special Ground Clearance Burning Permit-22 counties
in coastal N.C.. with organic soils.
On -site inspection by N.C. Division of Forest Resources required 'if more than five.
acres of ground clearing activities are involved. Inspections should be requested
at least ten days before actual burn is planned."
1 day
(N/A)
O
Oil Refining Facilities
N/A
90 -120 days
(N/A)
El
Dam Safety Permit
If permit required. application 60 days before begin construction. Applicant
must hire N.C. qualified engineer to: prepare plans, inspect construction. certify
construction is according to DENR approved plans. May also require permit under
mosquito control program, and a 404 permit from Corps of Engineers.
An inspection of site is necessary to verify Hazard Classification. A minimum
fee of 5200.00 must accompany the application. An additional processing fee
based on a percentage or the total project cost will be required upon completion.
30 days
(60 days)

PERMITS
SPECIAL APPLICATION PROCEDURES or REQUIREMENTS
N. .... _ SS Time
(Statutory Time'...imit)
Permit to drill exploratory oil or gas well
File surety bond of S5,000 with DENR running to State of N.C. conditional that any
well opened by drill operator shall, upon abandonment, be plugged according
to DENR rules and regulations.
10 days
y
(N/A)
Geophysical Exploration Permit
Application filed with DENR at least 10 days prior to issue of permit Application
by letter.No standard application form.
10 days
-(N/A)
-
State Lakes Construction Permit
Application fees based on structure size is charged. Must include descriptions
& drawings of structure & proof of ownership of riparian property.
15 - 20 days
(N/A)
0
401 Water Quality Certification
N/A
55 days
(130 days)
F0
CAMA Permit for MAJOR development
S250.00 fee must accompany application
60 days
(130 days)
❑
CAMA Permit for MINOR development
S50.00 fee must accompany application
22 days .
(25 days)
O
Several geodetic monuments are located in or near the project area. If any monument needs to be moved or destroyed, please notify:
N.C. Geodetic Survey, Box 27687 Raleigh, N.C.27611
0
Abandonment of any wells, if required must be in accordance with Title 15A.5ubchapter 2C.0100.
El
Notification of the proper regional office is requested if "orphan" underground storage tanks (USTS) are discovered during any excavation operation.
El
Compliance with 15A NCAC 2H 1000 (Coastal Stormwater Rules) is required.
45 days
(N/A)
*
Other comments (attach additional pages as necessary, being certain to cite comment authority)
•
Qu stions regarding these
Asheville Regional Office
59 Woodfin Place
Asheville, N.C. 28801
[phone]
❑ Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, N.C. 28301
[phone]
REGIONAL OFFICES
permits should be addressed to the
O Mooresville Regional Office
919 North Main Street
Mooresville, N.C.28115
[phone]
❑ Raleigh Regional Office
3800 Barrett Drive, P.O. Box 27687
Raleigh, N.C.27611
[phone]
❑ Washington Regional Office
943 Washington Square Mall
Washington, N.C. 27889
[phone]
Regional Office marked below.
O Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, N.C. 28405
[phone]
❑ Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, N.C. 27107
[phone]

RESPONSES TO DENR DRAFT EA REVIEW COMMENTS
Mr. Richard Betz, Highlands Town Administrator provided comments to RJG&A in
response to the Draft EA review comments from Todd Kennedy, DWQ (9 October 2002), Teresa
Rodriguez, DWQ (1 October 2002), and Owen Anderson, WRC (26 September 2002). The
following responses are primarily those of Mr. Betz, with further comments added by the
environmental consultants where applicable (in Times New Roman bold font).
1. DIVISION OF WATER QUALITY -- Todd Kennedy.
The first section, "Impaired Streams," refers to the recent report on the Upper Cullasaja River
Watershed and the impaired rating of Mill Creek. These comments, together with many of the
comments of the Wildlife Resources Commission, seem to focus wholly on water quality above
the WWTP discharge, and also seem to be based on a misunderstanding about the objective of
the VWVTP expansion.
The expansion of the plant will involve new tertiary treatment technology (as the WRC letter
admits), will not adversely impact the Cullasaja River, and faced no objection at the public
hearings. The proposed capacity is expected to provide treatment for existing development in
new areas, not new development. The service areas identified in the Preliminary Engineering
Report included several subdivided areas which the Town may consider annexing in the future,
as well as existing areas already within the corporate limits. All of these areas are already
subdivided, and many of the Tots are already developed residentially and are served with either a
package treatment plant (Highlands Falls outside of Town, Highlands Country Club and Shelby
Place inside of Town) or with subsurface septic tanks. The Town's objective is twofold: (1) to
eliminate the package treatment plants and incorporate them into the municipal system, and (2)
to make sewer service available both inside and outside of Town where failing septic systems are
likely, especially around the Town's water resources.
The ongoing program of eliminating package treatment plants is well underway. In September of
last year, the Town completed construction of a sewer collection line along the west shore of
Lake Sequoyah, which made possible the elimination of the Highlands Mountain Club package
plant and discharge. The S.B. Association plant (50,000 GPD) serving Highlands Country Club
and Shelby Place will be eliminated this year; an agreement is currently being reviewed, and the
NPDES permit will expire on November 30. As with the Highlands Mountain Club, which
consisted of 80 residential units constructed in the late 1970's, this capacity does not serve new
development; it serves existing subdivisions operating unreliable package treatment plants and
discharging into Lake Sequoyah, which was recently designated a Class 1 water supply reservoir.
In the 1996, the Town adopted a collection system policy which serves as the basis of placing
sewer system extension in its Capital Improvement Program:
"In considering sewerage system extensions, the Board shall first take into consideration the
public health and safety. First priority for extensions of the sewerage system shall be those areas
in close proximity to raw water intakes, such as the Lake Sequoyah and the Big Creek Arm of
Lake Sequoyah; those areas in close proximity to other streams or lakes; those areas where the
Board of Commissioners has agreed that an overall problem exists with regard to septic tanks
because of visible malfunction of systems and inadequate repair areas; and those areas where
the Board of Commissioners has agreed that older sewer service lines are in poor repair and/or
are subject to inflow and infiltration." [Highlands Code, 15247(b)]

In addition to the West Shore Lake Sequoyah collection line, a line was constructed along the
south shore of Mirror Lake and the north shore of Lake Sequoyah as part of the WWTP project.
This line made it possible to eliminate at least one package treatment plant, serving On the
Verandah Restaurant and discharging directly into Lake Sequoyah; it also made it possible to
elminate several residential septic systems. Collection lines have also been constructed along the
east shore of Big Creek on Hickory Hill Road, and along the south shore of Lake Sequoyah and
Munger Creek on NC106 this year. None of these collection lines served new development.
Existing businesses, such as Old Creek Lodge on NC106, are currently being served by an
inadequate septic system. The line also made possible the connection of a small residential
apartment building to the municipal sewer which had a history of repeated septic tank
malfunctions, resulting in numerous fines and notices of violation from the Asheville Regional
DENR office and the County Health Department.
The commercial downtown business district, which is bisected by Mill Creek, is already provided
with sewer service, and no expansion is planned or necessary in this area. The question, "How
will the Town prevent further degradation to these and other streams in the service area covered
by this VVVViP expansion?" is therefore meaningless with respect to the impaired strean, Mill
Creek, and the downtown area. Moreover, the Town's 1989 Land Use Plan resulted in extensive
"downzoning" from commercial to
residential, and thus there is no longer any significant potential for additional commercial
development in the business area. The one remaining property of any size, a 0.78 acre tract on
the corner of Pine Street and Fifth Street, is at least 300 feet from Mill Creek, and has direct
access to municipal sewer. The portion of Mill Creek which flows through the Town's recreational
park is undeveloped along the stream and by policy will remain that way.
The other service areas, such as Highlands Country Club inside Town and, potentially, Highlands
Falls Country Club outside of Town, will be protected from degradation through a stringently
enforced local Soil Erosion and Sedimentation Ordinance and Watershed Protection
requirements that exceed the requirements of the State (see below).
RJGA Comment: Mr. Kennedy notes that the WS-III-BW-Tr classification of Cullasaja River and
Mill Creek in the central developed portion of Highlands does not appear to adequately protect these
streams from urban impacts, based on their existing degraded condition. However, most oft e
development in this area pre -dates the Water Supply Watershed and Trout Stream Protection rules
by decades, and the protective measures imposed by those rules were never intended to undo existing
riparian damage. Impacts of future development under the existing rules would not be as damaging
as were past development practices.
*****
The second section, "Stormwater," refers to "few requirements that appear to provide protection
to water resources and aquatic habitat." The DWQ should be reminded that the Town has
enforced a local Soil Erosion Ordinance since 1984. The Ordinance features more stringent
requirements than the State's model ordinance, including a minimum 3000 SF required for a Land
Disturbing Permit (instead of 40,000 SF), and recentlyadopted requirements for full soil erosion
plans for singlefamily homes constructed on steeper slopes, regardless of the size of the
disturbed areas. Similarly, the Watershed Protection requirements, incorporated into the Zoning
Ordinance in 1993, go far beyond the State's minimum guidelines, including a 50foot natural
vegetative buffer in the Critical Area (instead of 30foot). The Ordinance also does not simply
"grandfather" existing substandard lots, as permitted by the Watershed Protection Act and as is
the case with most local govemments; instead, it strictly limits new "builtupon" development on
these lots, in most cases to 12%. The Town is not aware of another local government with
requirements as stringent as these.

The Town has not yet been required to adopt Stormwater Protection requirements, but is working
to mitigate possible stormwater impacts. The Town's Watershed Administrator, Engineer,
and
Planning staff recommend voluntary stormwater control efforts where applicable during the plan
review process. The new Child DevelopmentCenter on Church Street has received a grant to
"demonstration the Center to serve as an educational site" for stormwater treatment,
despite its lack of proximity to streams. A $25,000 sewer system evaluation is being ticonducted
by consulting engineers with W. K. Dickson Company to identify and correct stormwater
discharges into the sanitary sewer system, and to map the sewer system using GIS technology.
*****
The third section, "Stream Buffers," comments on natural vegetative buffers, which the Town
enforces with respect to the Watershed Protection Act. The Highlands Watershed Ordinance
permits clearing and re -planting of stream buffers provided that it complies with the local soil
erosion ordinance. According to a 1993 staff memo regarding the Watershed Ordinance: "There
is nothing in the regulations to prohibit gardening, landscaping, or other horticultural activities in
the buffer; the definition refers to "natural or planted vegetation." The applicable Sections in
Article 200 prohibit new development that constitutes "built -upon area" in the definition, such as
buildings, driveways, patios, etc.
"No new development is allowed in the buffer except for water dependent structures, as defined
by this Ordinance, and public projects such as road crossings and greenways where no practical
alternative exists. These activities should minimize builtupon surface area, direct runoff away
from the surface waters and maximize the utilization of stormwater Best Management Practices."
[Section 211.7(b)]
One hundred percent of the Town's service area is protected by these vegetative buffers, as the
entire Town (except for a small portion to the south and east) is located within a Public Water
Supply Watershed, 95% of which is classified WS-III.
No maps have been prepared of intermittent streams. However, voluntary buffer protection will be
encouraged around such streams through the Town's stringent environmental review of all new
projects by the Planning Board, Appearance Commission, Zoning Board, Town Engineer, and
Watershed Administrator.
RJGA Comment: The Highlands region receives exceedingly high rainfall and sustains base flows
during dry weather in tiny streams with minimal drainage basin area (Giese and Mason, 1991).
Consequently, Highlands has an unusually high density of perennial and intermittent streams, as
indicated on soil survey maps (Thomas, 1996). According to Mr. Betz, prohibiting new
development within 30 feet of intermittent streams would render many existing platted lots
undevelopable and would pose a significant loss of property value and tax revenues to Highlands.
The Town Commissioners would be unlikely to approve this measure. Increasing the required buffer
width on perennial streams to 100 feet would have similar economic problems and meet similar
opposition.
The final section, "Other Comments," again refers to "new development accommodated by this
VWVrP expansion," which has already been discussed.

2. NPDES UNIT -- Teresa Rodriguez.
The growth rates cited should be welldocumented in the Preliminary Engineering Report, and are
standard population projections based on data available. It should be pointed out, however, that
the growth rate projections are also corroborated by the flow projections from the WWTP itself,
which indicated a projected 1.5 MGD capacity. In addition, W. K. Dickson Company is working on
a corroboration of this capacity based on projected demand, area by area, pursuant to an earlier
sewer study.
The areas in question, as discussed previously, are served by either septic systems or private
package treatments plants. Town staff has had formal discussions with representatives from
Highlands Falls Country Club, Wildcat Cliffs Country Club, and Cullasaja Club, but no letters of
intent have been filed as of this date.
Operational conditions of onsite systems should be well -documented in the Asheville Regional
DENR office. There have been documented problems with the S. B. Association package
treatment plant, including notices of violation and fines from the Asheville DENR office. We
understand that the Highlands Falls Country Club package plant also received a notice of
violation recently.
The Preliminary Engineering Report should have adequately addressed the feasibility of reusing
wastewater on golf courses. There are no "proposed"golf courses anywhere in the area, only
existing golf courses already equipped with extensive irrigation systems. Highlands Country Club,
the only golf course located in the Town limits, irrigates from Club Lake. All of the golf courses in
the entire watershed, inside and outside of Town, were contacted and indicated that they were
unwilling to use treated effluent for irrigation.
3. WILDLIFE RESOURCES COMMISSION -- Owen Anderson.
The first page refers to endangered species such as the bog turtle. It is not clear how expansion
of the VVWfP could "adversely impact a federally threatened species."Any wastewater collection
lines proposed for the future (not part of this permit) would have to go through a permitting
process, and the Town would certainly agree to contact the U. S. Fish & Wildlife Service if there
were any endangered species affected.
We are pleased that the WRC made reference to the tertiary treatment, the minimal impact of
construction, and the benefit to aquatic life downstream. The Town regards itself as good
stewards of the enviroment and feels that it has a special responsibility to the Cullasaja River.
Tertiary treatment was proposed in order to maintain and improve water quality in the receiving
river; it is that area, not the Upper Cullasaja above the WWfP, which will receive the impact from
the discharge. Nevertheless, the letter claims that "the new infrastructure will provide a stimulus
for new development that will result in
increased land clearing, increased impervious surfaces, increased urban runoff, and unregulated
construction in streams and riparian areas." This is simply not the case. As discussed earlier, the
VWVfP will serve existing areas already subdivided; it will provide reliable, municipal sewer
service rather than subservice septic systems or private package treatment plants. This is
especially evident in developments like Highlands Country Club, Shelby Place, and Highlands
Falls Country Club, which have been entirely subdivided for years and are served by private
sewer; expansion of the municipal system to serve these areas by eliminating those private plants
will simply replace unreliable sewer service with reliable sewer service. In other areas, such as

Mirrormont subdivision, municipal sewer service would replace subsurface septic systems. And in
providing sewer service to areas such as NC106, where documented septic system problems
have existed for years, the project will have a beneficial impact on both aquatic life and public
health. Clearing of land areas, limiting of impervious surfaces, and "unregulated" construction no ction in
streams are strictly regulated or prohibited by both Town and County regulations. There
"unregulated construction" in Highlands.
It is unclear how expansion of the WVVTP would have any affect on the issues raised in the
specific items listed in the letter:
No. 1: New service areas which the Town would propose to develop would certainly be surveyed
as part of the sewer line projects approved by the State.
No. 2: No new development is proposed in any wetland or areas where there are endangered
species. The amount of wetlands in the Highlands watershed is very small, and the Town recently
adopted amendments of its Zoning Ordinance which would require approval by the U. y
Corps of Engineers before construction on any residential lots whatsoever that are deemed
wetlands.
No. 3: Although the VWVTP is being expanded to serve new areas, these are areas which are
already developed, many of them in subdivisions with other infrastructure already in places;
incorporation of the package sewer treatment plant serving all of Highlands Falls Country Club,
e.g., would require little more than a collection line from the plant to the nearest municipal sewer
line, not extensive construction. Collection lines to these areas would be placed in the Capital
Improvement Program as funding and necessity permit.
No. 4: The VW TP is already equipped with standby power; it was the only facility which
continued to operate during the Blizzard of 1996.
No. 5: The Ordinance Regulating the Draining of Impoundments, enforced currently in both the
Town and the County (the latter enforced through an interlocal agreement by the Town's
Watershed Administrator), is not only a "good idea," it is a groundbreaking Ordinance that we
understand is unique in the State. The 50 NTU standard was proposed by W. K. Dickson
Company, and the Ordinance was reviewed by DENR's Asheville Regional Office.
RJG&A Comment: The 50 NTU standard is the state-wide maximum turbidity standard, and is less
stringent than the 25 NTU standard for HQW/ORW streams and the 10 NTU trout stream standard.
These lower (more stringent) standards are not feasible to enforce due to sediment transport
dynamics that occur when a pond is drained. Fine silt and organic particles accumulate over many
years on the bed of a full pond, where little water movement occurs. As the pond is drained the
water velocity at the bed surface increases, resuspending these fine particles, even if draining occurs
very slowly.
No. 6: As previously discussed, the Town's Watershed Protection regulations address stormwater
runoff from residential development; natural vegetative buffers 50 feet in width in the Critical Area
and 30 feet in width in the Balance of Watershed area are required throughout the Town.
As to the guidelines which the WRC requests the Town to implement:
1. It would not be feasible in most cases to provide for the buffers indicated along perennial or
intermittent streams (see previous discussion). In any case, construction of sewer lines is not

proposed in proximity to any perennial streams, nor is any such construction proposed in the
permit application.
2. Sewer lines are not proposed in stream buffer areas; they are generally installed along roads in
Highlands.
3. The Town already regulates the removal of trees in commercial zoning districts, as authorized
pursuant to Special Act of the Legislature enacted in 1986 (Chapter 828, House Bill 1469). No
"construction corridors" are proposed as part of this permit.
4. There are no FEMA designated floodplains in Highlands, and thus the Town has no local .
floodplain regulations.
5. Impervious surfaces are limited to 6% (in WS-II-CA), 12% (in WS-III-CA), or 24% (in WS-111-
BW) on substandard Tots throughout the watershed under the Town's Watershed Protection
regulations.
6. No roadway crossings are proposed as part of this permit. There are no projects involving
bridges or culverts planned for any streams or associated wetlands in Highlands.
7. The Town enforces a local Soil Erosion and Sedimentation Ordinance, and has since 1984.
The Ordinance contains all of the elements listed in (a) through (i), as well as the additional
provisions discussed earlier.