20220861 Ver 1_9-12-2022 Info Received_20220912

Annino, Amy M
From: Tyson Kurtz <[e-mail]>
Sent: Monday, September 12, 2022 11:41 AM
To: Annino, Amy M
Subject: RE: [External] FW: Crabtree Mountain Road Campground NWP 39 - Action ID SAW-2022-01384
Attachments: Fig 5 Wetland and Stream Impacts Rev - 11x17 - Highlighted.pdf; Stream Impact Table with Culvert
Lengths.pdf, Crabtree Mountain Road Campground.pdf, Crabtree Road Cam pground-Certificate of
Coverage for Phase 1.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Amy,
Please see the responses to your comments and question below in RED. Please also see the referenced attachments.
Wetland names referenced below are on the PJD request delineation map that was included in Appendix A of the
original submittal and again on the email dated July 19, 2022 around 4pm after the JD visit (you were cc'd).
Thank you,
Tyson Kurtz
Biologist
0: 828-698-9800 ext. 302 1 C: 610-310-8744
From: Annino, Amy M <[e-mail]>
Sent: Wednesday, August 17, 2022 3:28 PM
To: Tyson Kurtz <[e-mail]>
Subject: RE: [External] FW: Crabtree Mountain Road Campground NWP 39 - Action ID SAW-2022-01384
Hi Tyson,
No additional work should be conducted at this site until DWR has issued the 401.
Please see my additional information request below. Feel free to contact me with any questions.
On June 22, 2022, the Division of Water Resources (Division) received your application requesting a 401 Water Quality
Certification from the Division for the subject project. On June 30, 2022, the Division received the required fee. Upon
review of that response, the Division has determined that your application is incomplete and cannot be processed. The
application is on -hold until all of the following information is received:
PCN Impact Table
• DWR requests that you include information in a table showing the original culvert length for sites where culverts
were replaced and whether they were lengthened or shortened.

o The stream impact table from Section C3 of the submitted permit application has been updated to show
lengths of existing culvert replacements, where applicable (attached).
• Please also indicate for each impact if the work has already been performed and whether the work was
performed in the dry to meet DWR conditions.
o All impacts to wetland and streams on site have been conducted except for bank stabilization impacts
(S9-S13), which will be conducted prior to October 15. Culvert installations were not conducted in the
d ry.
Impact map
• Please enumerate all wetland and stream impacts including fill / dissipater pads/ etc. on the site plans and
clearly label all impacts (Wetland/ Stream Impact 1, etc.). The Division recommends highlighting by hatching or
shading all impacts areas for temporary impact areas and permanent impact areas. [15A NCAC 02H
.0502??].0502(a)(9)
o Refer to Figures 5.0 - 5.11 of the supplemental information submitted via email on July 22, 2022. Figures
were reattached with impacts highlighted. All impacts were identified as S1, W1, etc. and highlighted
with red/crosshatching in the original submittal.
The stream channels are not shown on the site plan. Please explain why and/or provide an overlay showing
jurisdictional streams on the site plan detail sheets with proposed impacts. [15A NCAC 02H .0502??].0502(a)(9)
o All the delineated streams and wetlands were shown on Figure 5.0-5.10 of the original submittal. The
revised figures 5.0-5.11 of the July 22, 2022, supplemental information, included one change in the
delineation. The stream call at former stream impact location S5 was changed to linear wetland and is
now shown as wetland impact W6.
Culvert impact length
As indicated under Item C.3.g (Page 13) of the USACE PCN Complete Help File "The stream impact length should
be measured along the centerline of the stream. When proposing a culvert, the impact length is generally greater
than the length of the culvert and associated dissipater since the existing stream usually has some sinuosity
(curvature)." Please verify or correct the stream impact length as indicated on the PCN form. Please provide
updated drawings and application materials (including Table of Impacts in the PCN form) that properly show the
length of impacts to the jurisdictional stream. [15A NCAC 02H .0502(a) and (c)](a)(9)]
o The stream impact length was calculated along the stream centerline. As shown in the original submittal
and again on the revised Figures 5.0-5.11 of the July 22, 2022, supplemental information, the stream
impact length is longer than the installed culvert length or the difference in length of culvert
replacements. Figures 5.0-5.11 are attached with highlighted stream impacts labels that include the
culvert replacement details .
Coir matting
• Please address how the requirement to use coir matting adjacent to streams and wetlands will be met per the
required Condition 11.6 of the attached GC4263.
o Matting with plastic mesh or plastic twine was not used along stream banks or within wetlands.
Grade control
Please provide calculations to show the outlet velocity from the proposed 81 LF culvert outlet(s) discharging into
the wetlands W6 and W4. A non -erosive velocity of two feet per second or less must be achieved for the peak
flow from the 10-year storm. [15A .02B .0231]
o The culvert outlet from Wetland Impact W6 in Wetland WHH has a T-Outlet structure with rip rap on
either side to dissipate energy prior to discharging into the wetland. The T-Outlet structure was not
shown on Figure 5.5, but a generalized typical detail of the installed energy dissipator is included below.
This impact area (W6) accounted for the area of this structure.

■ *riprap dissipater pads installed (on site) at each side of the t-outlet are not shown in the detail.
o Wetland impact W4 accounts for a rip rap energy dissipater below the culvert outlet to protect Wetland
WKK. This was shown in the original submittal and again on Figure 5.5 of the supplemental information
submitted via email on July 22, 2022.
o Outlet velocities were designed to match or to lessen outlets velocities of pre -construction culverts.
0 15A NCAC .02B .0231 does not state any requirements for the referenced discharge velocity into
wetlands. The applicant believes the energy dissipaters installed at the culvert outlets at Wetland
Impact areas W6 and W4 provide protection to the receiving wetlands. The Corps and NC WRC saw and
verbally approved of the energy dissipaters at the W4 and W6 culvert outlets during the July 14, 2022,
site meeting.
• DWR is concerned that the velocity at the culvert outlets will impact the stability of streambeds due to the
extremely steep slopes of the culverts. Please discuss how the existing grade of the streambeds at culvert
outfalls will be maintained.
o Please refer to the supplemental email submitted July 22, 2022, noting additional bank stabilization
measured to be installed at culvert outlets that appear to be susceptible to erosion. Boulder bank
stabilization will provide stability to the stream bed below the culvert outlets.
Impact Clarification
• S1 Impact
o Please indicate on the site plan the type of fill proposed / implemented.
■ A culvert was installed under the roadbed from Wetland Impact W1 to the undisturbed stream
channel (SM) below Stream Impact S1.
o W1 is shown to be isolated. Was W1 connected to S1 prior to unpermitted project activities?
■ No, WEE (where Wetland Impact W1 occurred) did not have a surface connection to SM (where
Impact S1 occurred). It is possible there was an old crushed or wooden culvert in this location
but it was not obvious during the wetland and stream delineation that was conducted prior to
the road improvements in this location.
• W3 Impact
o Please indicate what the fill impact is for this location. Please discuss/demonstrate how the wetland
above W3 impact will not be hydrologically disconnected from the wetland W3 impact.
■ The wetland impact table in section C3 and Figure 5.6 of the original submittal and the
supplemental information, provided July 22, 2022, specify W3 is an excavation impact for
grading along the roadside. The hillside around Wetland Impact W3 was excavated/graded to
provide a stable slope next to the road. Hydrology from the unimpacted section of Wetland WILL
above the road re-created a channel with surface water flow down to the culvert that was
installed under the road. The culvert system receiving this surface water directly connects to
wetland WKK.
3

• W5 Impact
o Please indicate on the site plan the type of fill proposed.
■ Wetland Impact W5 was for excavation into the hillside to create a stable slope adjacent to the
improved access road. Refer to Figure 5.9 of the supplemental information submitted via email
on July 22, 2022.
o The wetlands below W5 impact should not be hydrologically disconnected the wetland above the W5
impact. Please discuss/demonstrate how these wetlands will not be hydrologically disconnected from
project activities.
■ A culvert was installed under the roadbed to maintain surface water hydrology between the
upslope and downslope wetlands. During the July 14th, 2022, site visit with the USACE and NC
WRC, this impact area was inspected. Wetland WILL, upslope of W5 impact area, recreated a
seep with surface water flow along the graded slope that remains connected to WILL between
the access roads via a culvert installed under the roadbed (not shown on Figure 5.9).
W4 impact
o Please discuss/demonstrate how the upper portion of the wetland at this location will not be
hydrologically disconnected to the rest of the wetland area.
■ Wetland impact area W4 (to wetland WJJ) does not disconnect any portions of the wetland. The
wetland upslope are all connected to WKK and downslope streams via culverts or surface water
within unimpacted wetland areas of WILL.
• W6 culvert outfall
o Please discuss how
■ We do not understand this incomplete comment.
Site stability
• Please specify a native seed mix for stabilization of any temporary streambank /wetland impacts. Please provide
a timeline for application and stabilization.
o Species used to revegetate the site and for erosion control are specified by the Division of Energy,
Mineral, and Land Resources (DEMLR), Land Quality Section. Erosion control measures will be in
compliance with DEMLR Standards.
o A copy of the DEMLR and Haywood County Erosion Control Plan approval letters are attached for
reference.
Species used to revegetate the site and for erosion control are specified by the Division of Energy, Mineral, and Land
Resources (DEMLR), Land Quality Section. Erosion control measures will be in compliance with DEMLR Standards.
• Permanent seed should be applied as quickly as possible for stabilization across the site to ensure sediment is
not lost to surface waters or wetlands. Please provide a timeline for when this will be achieved.
o Species used to revegetate the site and for erosion control are specified by the Division of Energy,
Mineral, and Land Resources (DEMLR), Land Quality Section. Erosion control measures will be in
compliance with DEMLR Standards.
o A copy of the DEMLR and Haywood County Erosion Control Plan approval letters are attached for
reference.
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested information for the
proper consideration of the application. Please provide your response by September 17, 2022. If all of the requested
information is not received, the Division will be unable to approve the application and it will be denied as incomplete.
The denial of this project will necessitate reapplication to the Division for approval, including a complete application
package and the appropriate fee.

Amy Annino
Environmental Specialist — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
828 296 4656 office
984 232 1222 mobile
amy.annino(cancdenr.gov
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are
on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time.
From: Tyson Kurtz <[e-mail]>
Sent: Friday, July 29, 2022 8:51 AM
To: Annino, Amy M <[e-mail]>
Subject: [External] FW: Crabtree Mountain Road Campground NWP 39 - Action ID SAW-2022-01384
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Amy,
David Brown issued the NWP 39 for the project. I wanted to follow up to see if you had any questions regarding the
application or the additional information I sent to you and David (July 22) after the site meeting .
David is enforcing that the culvert outlet bank stabilization work needs to be conducted prior to October 15. Does the
bank stabilization work need to wait until the 401 WQC is issued?
If the proposed bank stabilization work was a standalone project, it would be non -notifying, but since it is paired with
permanent wetland and stream impacts on site, I am not certain if they need to wait for authorization.
Thank you,
Tyson Kurtz
Biologist
0: 828-698-9800 ext. 302 1 C: 610-310-8744
From: Brown, David W CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, July 28, 2022 10:10 AM

To: [e-mail]
Cc: Tyson Kurtz <[e-mail]>; Tim V. Surrett <[e-mail]>
Subject: Crabtree Mountain Road Campground NWP 39 -Action ID SAW-2022-01384
Matt Bare,
Reference is made to the pre -construction notification submitted by ClearWater Environmental Consultants for the
utilization of NWP 39 for the Crabtree Mountian Road Campground development project in Clyde, Haywood County,
North Carolina. Attached is the Corps' general permit verification for the project. As part of the Corps efforts for
paperless communications, no hard copy will be mailed.
Sincerely,
David Brown, PG
Regulatory Specialist/Geologist
USACE Wilmington District -Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
828-271-7980, ext. 4232
[e-mail]