20080303 Ver 1_Mitigation Plan Review_20080222

NC Division of Water Quality
401 Oversight and Express Permitting Unit
February 22, 2008
Memorandum
To: Cyndi Karoly
Ian McMillan
Kevin Barnett
File
From: Eric Kulz
Subject: DWQ # 20080303
Comments on Individual Permit Application and Mitigation Plan -Webster Creek Golf
Course and Residential Community
Jackson County
Application and Mitigation Plan prepared by WNR
The applicant is proposing to construct a Mickelson Championship Golf Course, apar-three golf
course, a driving range, and a mixed single-family/multi-family residential community1,810 acres
of land.
There are approx. 54,000 LF of streams on-site. Proposed impacts are 3,890 LF (550 LF for road
crossings and 3,340 LF for golf course impacts). Some of the streams are trout streams, and
trout have been documented by WNR in Webster Creek. Wetland impacts total 0.48 acres (0.03
ac. For road crossings and 0.46 for golf course impacts).
On-site mitigation is proposed, to consist of enhancement of 4,542 LF of stream, restoration of
0.96 ac. of wetlands. Also included is preservation of 40,000 LF of stream and 4.5 ac. wetlands.
Bold comments are for the letter
Comments on the impacts:
While it appears that they layed out the course to avoid impacts to some extent, there are a lot of
areas where streams will be piped beneath the course. The driving range is aligned in the
middle of a stream valley, and will result in the piping of 847 LF of stream and 0.317 ac. of
wetlands. This needs to be redesigned or reconfigured to reduce impacts.
Road crossing 17 is a short road to nowhere located southeast of the equestrian barn. The
purpose and need for crossing 17 needs to be provided.
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
http://ncwaterq uality.org/wetlands

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NC Division of Water Quality
401 Oversight and Express Permitting Unit
Comments on the mitiaation plan:
I have questions in general regarding the level of work needed on these streams. They have no
vegetated buffers, so Enhancement II seems appropriate. I question the need for bank sloping at
all but the most damaged areas. In most of the photos, the stream bed looks good, with cobble
and boulders, and trout have been documented in Webster Creek. This site may warrant a site
visit to look at the conditions of the streams.
DWQ questions the justification for bank re-sloping in all but the most damaged
streambank areas. Photos show undercut banks and indicate that the banks are to be re-
worked. Undercut banks provide valuable habitat, and if root material is present, these
undercut areas can be stable. Similarly, DWQ questions the addition of rock vanes, j-
hooks or other structures in the streams. It is not clear that these structures are needed.
DWQ favors planting buffers along the streams and generally avoiding in-stream work,
with the exception of the locations where culverts are removed. If in-stream structures are
determined to be necessary, it is critical that they be installed such that aquatic life
passage is ensured.
The mitigation plan proposes on-site preservation of 40,689 LF of streams and 3.05 acres
of wetlands. Please confirm that this preservation will include placing these stream and
wetlands within a conservation easement.
I also question the credit ratios used in the plan. Theyy are proposing 1:1 for Enhancement I, and
1.5:1 for Enhancement II. Obviously, these are the most favorable of the sliding ratios. They are
also proposing preservation with 30-foot buffers at 5:1, but with 50-foot buffers they are asking
for 2.5:1. Kevin Barnett has contacted Lori Beckwith at USACE to look at these.
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
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