20060616 Ver 1_Site Plan_20060606

4041401 INDIVIDUAL PERMIT APPLICATION
for:
LAURELMOR DEVELOPMENT
6050 -Acre Tract
WATAUGA and WILKES COUNTIES, NORTH CAROLINA
Prepared for:
Ginn -Laurel Creek GP, LLC
389 Little Laurel Road Extension
BOONE, NORTH CAROLINA 28607
Prepared by:
E'nV Environmental Consulting Services, Inc.
3764 Rominger Road
BANNER ELK, NORTH CAROLINA 28604
February 1, 2006

TABLE OF CONTENTS
404 Application (ENG FORM 4345) ...........................................................
1
Addendum to ENG FORM 4345 ................................................................
3
LocationMaps .......................................................................................
5
Project Narrative ...................................................................................
11
Jurisdictional Determination Maps ............................................................
29
PermitMaps .......................................................................................
40
Avoidance, Minimization & Mitigation Narrative ..........................................
64
Details and Cross-sections ......................................................................
72
Appendix A. Adjacent Land Owners to Laurelmor Property ..........................
76
Appendix B. Listing of Acquired Permits ...................................................
81
Appendix C. Laurelmor Project Photo Sheets ............................................
85
Appendix D. North Carolina Division of Forest Resources Letter ...................
88
Appendix E. Public Access Fishing Policy .................................................
89
Appendix F. Alternative Lake Overview Map .............................................
90
Appendix G. Alternative Golf Course Layout ..............................................
91
List Of Figures
Figure 1.
County Wide Map of Laurelmor Project ..........................................
5
Figure 2.
Regional Map of Laurelmor Project ...............................................
6
Figure 3.
Topographic Map of Project Site at 1 -100,000 scale .........................
7
Figure 4.
Deep Gap, Buffalo Cove, Maple Springs USGS topo quad ................
8
Figure 5.
Project Boundary with Topographic Map at 1-24,000 scale ................
9
Figure 6.
2004 True Color Aerial Photograph .............................................
10
Figure 7a
— 7j. Jurisdictional Determination Maps ...................................
29-38
Figure 8.
Laurelmor Watershed Boundary Map ..........................................
39
Figure 9a
— 9d. Laurelmor Development Master Plan ..............................
40-43
FigurelOa-101. Laurelmor Impact Maps Permanent .............................
44-55
Figure 11 a — 11 d. Laurelmor Temporary Impact Maps .............................
56-59
Figure 12.
Proposed Bridge Location Map ................................................
60
Figure 13a — 13c. Laurelmor Habitat and Conservation Maps ...................
61-63
Figure 14.
French Drain Impact Detail ......................................................
72
Figure 15.
Lake Fringe Detail .................................................................
73
Figure 16.
Typical Road Section Detail .....................................................
74
Figure 17.
Typical Dam Section Detail .....................................................
75
List Of Tables
Table 1.
Stream Drainage Data ...............................................................
14
Table 2.
Proposed Permanent Impacts .....................................................
16
Table 3.
Proposed Bridge Stream Crossing ...............................................
18
Table 4.
Estimated Impervious Coverage at Maximum Build -out ...................
19
Table 5.
Summary of Resources Identified in Dugger Creek Tract ..................
26
Table 6.
Alternative Lake Analysis ..........................................................
68
Table 7.
Alternative Golf Course Layout Analysis .......................................
68

APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT OMB APPROVAL NO. 0710-0003
(33 CFR 325) 1 Expires December 31, 2004
The Public burden for this collection of information is sestimated to average 10 hours per response, although the majority of applications should require
5 hours or less. This includes the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and
completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of
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Operations and Reports, 1215 Jefferson Davis Highway, Suite 1204, Arlington, VA 22202-4302; and to the Office of Management and Budget,
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no person shall be subject to any penalty for failing to comply with a collection of information if it does not display a currently valid OMB control
number. Please DO NOT RETURN your form to either of those addresses. Completed applications must be submitted to the District Engineer having
jurisdiction over the location of the proposed activity.
PRIVACY ACT STATEMENT
Authorities: Rivers and Harbors Act, Section 10, 33 USC 403; Clean Water Act, Section 404, 33 USC 1344; Marine Protection , Research and
Sanctuaries Act, 33 USC 1413, Section 103. Principal Purpose: Information provided on this form will be used in evaluating the application for a
permit. Routine Uses: This information may be shared with the Department of Justice and other federal, state, and local government agencies.
Submission of requested information is voluntary, however, if information is not provided the permit application cannot be evaluated nor can a permit
beissued.
One set of original drawings or good reproducible copies which show the location and character of the proposed activity must be attached to this
application (see sample drawings and instructions) and be submitted to the District Engineer having jurisdiction over the location of the proposed
activity. An application that is not completed in full will be returned.
OTEMS I THRU 4 TO BE
FILLED BY THE CORPS)
1, APPLICATION NO.
2. FIELD OFFICE CODE
3. DATE RECEIVED
1 4. DATE APPLICATION COMPLETED
5. APPLICANT'S NAME
8. AUTHORIZED AGENT'S NAME AND TITLE (an aqent is not reautred)
Ginn LA Laurel Creek, Ltd. LLLP
Doug Miller, Exec. Vice President
6. APPLICANT'S ADDRESS
9. AGENT'S ADDRESS
389 Little Laurel Road Ext.
Same
Boone, NC 28607
T. APPLICANT'S PHONE NOS. W/AREA CODE
10. AGENT'S PHONE NOS. W/AREA CODE
a. Residence
a. Residence
b. Business 828-263-5900
b. Business 828-263-5900
11, STATEMENT OF AUTHORIZATION
I hereby authorize, I to act in my behalf as my agent in the processing of this application and to
iurnish, upon request, supplemental information in support of this permit application.
APPLICANT'S SIGNATURE DATE
NAME, LOCATION AND DESCRIPTION OF PROJECT OR ACTIVITY
12. PROJECT NAME OR TITLE (s�instutin,,(
Laurelmor
'13. NAME OF WATERBODY. IF KNOWN af—oii—ivj 14. PROJECT STREET ADDRESS af.pp#,.b1,)
Swift Ford Branch Du--er Creek Laurel Ck I
I 1 -)0() T4� T � TD A u �
� -ul x
Boone, NC 28607
15. LOCATION OF PROJECT
Watauga and Wilkes North Carolina
COUNTY STATE
16. OTHER LOCATION DESCRIPTIONS, IF KNOWN, (s�instructios)
See attached Block 16.
17. DIRECTIONS TO THE SITE
From Boone, NC: Take US Hwy. 421 South out of town toward Wilkesboro, cross the South Fork of
the New River, go approximately 2 miles and turn right a stop light by the Food Lion onto old
Hwy 421. Go to intersection Elk Creek Road (approx. 2 miles), turn right and go approx 11.5
miles, site entrance and construction office is on the right. See location Map.
ENG FOR 345, Jul 97 EDITION OF FEB 94 IS OBSOLETE. (Proponent: CECW-OR)

1 S. Nature of Activity (Description of project, include a# teatures)
See attached Block 18.
19. Project Purpose (Describe the reason or purpose of the project, see instructions)
The proposed Laurelmor development will be a large low density residential resort golf course
community. An integral component of this community will be the two 18 -hole championship golf
courses. (see attached Block 19)
USE BLOCKS 20-22 IF DREDGED AND/OR FILL MATERIAL IS TO BE DISCHARGED
20. Reason(s) for Discharge
All fill material to be permanently placed in or over Waters of the US is associated with
the proposed golf course construction. (see attached Block 20)
21. Tvpe(s) of Material Being DischarQed and the Amount of Each TVDe in Cubic Yards
Material proposed to be discharged will consist of either, 1)clean mineral soil fill in the
dam fill areas (450 cubic yards), or washed stone and perforated pipe fill (see Block 21)
22. Surface Area in Acres of Wetlands or Other Waters Filled (see instructions)
The total area of jurisdictional Waters of the US filled is 0.678 acres. This figure does not
include the area of streams or wetlands that will be flooded.
23. Is Any Portion of the Work Already Complete? Yes = No = IF YES. DESCRIBE THE COMPLr=TFD WORK
No jurisdictional Waters of the US have been filled or flooded to date, the only activities
that have commenced on the project site are the construction of roads and the preliminary
grading for two golf holes. All commenced activities occur in uplands (see attached Block 23)
24. Addresses of Adjoining Property Owners, Lessees, Etc., Whose Property Adjoins the Waterbody (if more than can be entered here,
please attach a supplemental list),
There are a total of 92 adjacent properties, 67 in Watauga County and 25 in Wilkes County.
These are listed in the appendix under Adjacent Landowner List (Block 24).
25. List of Other Certifications or Approvals/Denials Received from other Federal, State or Local Agencies for Work Described in This Application.
'NA
AGENCY TYPE APPROVAL* IDENTIFICATION NUMBER DATE APPLIED DATE APPROVED DATE DFNIFF)
see Block 25
attached
)uld include but is not restricted to zoning, building and flood plain permits
26. Application is hereby made for a permit or permits to authorize the work described in this application. I certify that the information in this
app6cation is complete and accurate. I further certify that I possess the authority to undertake the work described herein or am acting as the
duly authorized agent of the applicant.
SIGNATURE OF APPLICANT
DATE
SIGNATURE OF AGENT
DATE
The application must be signed by the person who desires to undertake the proposed activity (applicant) or it may be signed by a duly
authorized agent if the statement in block 11 has been filled out and signed.
18 U.S.C, Section 1001 provides that: Whoever, in any manner within the jurisdiction of any department or agency of the United States
knowingly and willfully falsifies, conceals, or covers up any trick, scheme, or disguises a material fact or makes any false, fictitious or
fraudulent statements or representations or makes or uses any false writing or document knowing same to contain any false, fictitious or
fraudulent statements or entry, shall be fined not more than $ 10,000 or imprisoned not more than five years or both.

Addendum ENG FORM 4345
ENG FORM 4345
Addendum to Application Form
1-20-2006
Block 16:
The study site begins about two miles below the Blue Ridge Parkway and is
situated between Sampson Road (State Road 1526) to the west and Elk Creek
Road (SR 1508) to the east (Figures 1 & 2). The area delineated is located on
the Deep Gap, Buffalo Cove, and Maple Springs topographical maps and roughly
has a central latitude of 36009'N and longitude of 81 o32'W (Figures 3-5).
Block 18:
Laurelmor consists of approximately 6050 acres, designed as a low-density
residential destination resort community containing approximately 1200 individual
lots. This community will be served by over 50 miles of roads, and a privately
owned and operated water and sewer utility system. There are also
approximately 950 multi -family townhome and condominium units proposed that
will be located in several cluster development areas. The residential community
will be served by an array of amenities including two 18 -hole championship golf
courses, a large indoor water park, an equestrian center, vineyard, restaurants,
and recreational trails (see Figure 9/1-aurelmor Master Plan map). A
comprehensive conservation plan is being prepared to identify areas to be
preserved as permanent easements held by a local land trust (see Figure 13).
Within the easement areas will be an extensive trail system to accommodate
primarily pedestrian traffic with some areas suitable for equestrian or mountain
bike use.
Permanent impacts to Waters of the United States are proposed to occur at ten
locations within the project area. All the projected impacts are associated with the
construction of two proposed 18 -hole championship golf courses. There are five
proposed impoundments and five proposed areas where portions of streams are
to be piped. The impacts will consist of inundation and filling of waters of the US,
including perennial streams, intermittent streams and wetlands for the purpose of
constructing dams and creating five impoundments and for the grading and
construction of four golf holes and the proposed driving range. Total impacts from
the proposed activity are limited to 0.18 acres of wetland impact and 6331 linear
feet of stream impact. The stream impact is divided into 4413 linear feet of
impact to perennial streams and 1918 linear feet of impacts to intermittent
streams. Impacts are further divided into those associated with piping or filling
and those impacts associated with inundation of undisturbed streams or
wetlands. The locations of these impacts are shown on Impact Maps (Figures
1 Oa -1 01) and Table 2 provides specific impacts at each impoundment.
There will be 25 locations where utility lines, primarily sewer lines, will cross
jurisdictional Waters of the US. All of these crossings will involve temporary
impacts to streams that will impact less than 25 linear feet of streambed and will
Laurelmor 404/401 Page 3 of 94 2/1/2006

Addendum ENG FORM 4345
be restored immediately following the installation of the pipe (Figure 11 a-1 1 d).
The maximum amount of temporary impacts to Waters associated with utility line
crossings will be 625 linear feet.
Block 19:
The proposed Laurelmor development will be a large low-density residential
resort community. An integral component of this community will be the two 18 -
hole championship golf courses. All of the proposed permanent impacts to
Jurisdictional Waters of the US are associated with the construction of these golf
courses. Without these golf courses this development would not be viable.
Block 20:
All fill material to be permanently placed in or over Waters of the US is
associated with the proposed golf course construction. This fill is either
associated with dam construction for one of the four proposed impoundments or
is associated with french draining small intermittent streams that could not be
avoided in the golf course area (Figure 14).
Block 21:
Material proposed to be discharged will consist of either, 1) clean mineral soil fill
in the dam fill areas (450 cubic yards), or washed stone and perforated pipe fill in
the golf course intermittent stream fills (157 cubic yards). The remaining impact
areas will be ungraded or filled flooded areas.
Block 22:
The total area of jurisdictional Waters of the US proposed to be filled is 0.678
acres. This number does not include the area of streams or wetlands that will be
flooded.
Block 23:
No jurisdictional Waters of the US have been filled or flooded to date, the only
activities that have commenced on the project site are the construction of roads,
preliminary grading for two golf holes, the construction of access roads to water
supply well locations and the drilling of several wells. All commenced activities
occur in uplands and all required permits have been obtained for all commenced
activities. No work authorized under the previously issued 404 and 401 permits
has commenced.
Block 24: see Appendix A
Block 25: see Appendix B
Laurelmor 404/401 Page 4 of 94 2/1/2006

Pea,
Kellersvil
Flymm,
*Map not to scale
Figure 1
nate location
Imor Project
'atauga Co.
Laurelmor 404/401 Page 5 of 94 2/1/2006

Figure 2
VICINITY MAP FOR
LAURELMOR PROJECT
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:tv Elk Park
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+ Approximate location of Latirelmor Project
Laurelmor 404/401 Page 6 of 94 2/1/2006

Figure 3
*Map not to scale
Approximate boundary of Laurelmor project area
Laurelmor 404/401 Page 7 of 94 2/1/2006

Figure 4
Laurelmor 404/401 Page 8 of 94 2/l/2006

Figure 5
*Map not to scale
Approximate boundary of Laurelmor Project
Laurelmor 404/401 Page 9 of 94 2/1/2006

Figure 6
Laurelmor 404/401 Page 10 of 94 2/l/2006
0
ct
C.)
. Ed

Project Narrative
LAURELMOR PROJECT
404/401 Permit Application
Project Narrative
Introduction:
Laurelmor is a multi -faceted destination resort development located on the
escarpment of the Blue Ridge physiographic region in western North Carolina
within the Elk and Blue Ridge Townships of Watauga and Wilkes Counties. The
entire site lies within the Yadkin River Basin. The project site consists of an
approximate 6050 -acre tract containing portions of 7 distinct drainage areas
(Figure 8). These are:
1. Laurel Creek including the South Fork of Laurel Creek (northwest)
and Laurel Creek (northeast)
2. Elk Creek (east)
3. Horton Branch (west)
4. Dugger Creek (central)
5. Little Dugger Creek (southeast)
6. Joes Creek (far west)
7. Tonys Branch (south central)
The applicant is Ginn -LA Laurel Creek, Ltd. LLLP (Applicant), owner of the
Laurelmor property. The Applicant purchased the project site from Kaplan
Holdings LLC in 2004. Kaplan Holdings LLC had previously applied for and
obtained a Clean Water Act 404/401 permit on a 1200 -acre portion of this same
site for the construction of a golf course resort community. The Applicant has
maintained the original Kaplan Holdings site in compliance with all conditions of
the original permit. In this application, Ginn seeks a new permit for a new project
plan and scope.
Project Location:
Laurelmor is located on an escarpment of the Blue Ridge physiographic region in
western North Carolina within the Elk and Blue Ridge Townships of Watauga and
Wilkes Counties. The study site begins about two miles below the Blue Ridge
Parkway and is situated between Sampson Road (State Road 1526) to the west
and Elk Creek Road (SR 1508) to the east (Figure 1-2). The project area is
located on the Deep Gap, Buffalo Cove, and Maple Springs topographical maps
(Figures 3-5) and roughly has a central latitude of 36009'N and longitude of
81032'W. Access to the property is primarily from Dugger Fire Tower Road (via
Sampson Road from the Blue Ridge Parkway) to the west and a recently
improved entrance road off Triplett Road (Elk Creek Road) to the east. Less
improved entry points are located around the periphery of the site and accessed
via private property.
The proposed project will involve the entire 6050 -acre tract and consist of a
dispersed low-density single-family residential community containing
Laurelmor 404/401 Page 11 of 94 2/1/2006

Project Narrative
approximately 1200 individual single-family residential lots. This community will
be served by approximately 50 miles of roads, and a privately owned and
operated water and sewer utility. There are approximately 950 multi -family
townhome and condominium units proposed that will be located in several cluster
development areas. The residential community will be served by an array of
amenities including two 18 -hole championship golf courses, a hotel, large indoor
water park, an equestrian preserve, vineyard, restaurants, Fire Department, a
trail network, and other recreational facilities. A comprehensive conservation plan
is being prepared to identify areas to be preserved through permanent
easements held by a local land trust. Within the easement areas, there will be an
extensive trail system to accommodate primarily pedestrian traffic but with some
areas suitable for equestrian or mountain bike use.
The project has been carefully designed to avoid and minimize impacts to Waters
of the United States. For example, the project contains 64 miles of jurisdictional
streams, but the 50 miles of roads crosses streams only 23 times. Each of those
crossings will be designed as non -impact crossings. The Applicant has also
continuously evaluated its golf course and infrastructure layouts and worked to
stay clear of jurisdictional areas to the maximum extent practicable and to select
and implement the least environmentally damaging practicable alternative. The
company's efforts are detailed more fully in this application package. As
described below, the project meets the mitigation sequencing steps
contemplated by the 404(b)(1) guidelines and the requirements of the Corps'
public interest review.
Existing Land Use:
The project area consists primarily of undeveloped forested land. Logging
occurred throughout the site in the late 1930's and early 1940's and was followed
immediately by a substantial fire that burned across the property. A small portion
of the land (-50-acres) was cultivated throughout the first half of the 2 Oth century
and was located around the historic homesteads reported on the property. The
cultivated land became fallow around 1950 and has since reverted to mature
forest. There has been relatively little human activity across the greater part of
the site. A second timber harvest occurred within select areas of the property in
the late 1980's and resulted in the construction of numerous logging and skid
trails. There are numerous first order streams that still suffer from the excessive
erosion and sedimentation induced by that period of logging. There are no
buildings currently located on this tract and the only structures on-site include an
old fire tower atop Dugger Mountain and a simple camping shelter located along
Dugger Creek. Road improvements from Triplett Road and along ridges have
been the primary recent land use of property.
Topography:
Laurelmor is representative of valley and ridge topography common throughout
the Blue Ridge Mountains. Rugged ridges and steep side slopes (30-50%)
typically characterize the uplands throughout this site. Vertical and near vertical
Laurelmor 404/401 Page 12 of 94 2/1/2006

Project Narrative
rock outcroppings are frequent across the property. Scree fields, formed by an
accumulation of unconsolidated rock debris, are present along mid to upper
coves in the northwestern portion of the property. Valley bottoms along streams
are generally narrow and steep to moderately sloping. Benches above channels
and along side slopes are relatively infrequent. Elevations across the site in
general decrease as one travels southeast across the site and range from
approximately 3500 feet above mean sea level along Mast Knob ridge to around
1400 feet at the confluence of Dugger Creek and Little Dugger Creek.
Stream and Wetland Delineation:
All streams and wetlands on the site have been delineated and mapped and all
stream corridors will be buffered with a minimum 30 foot -wide vegetated buffer
as required in areas designated as ORW. All designated trout streams will have a
minimum undisturbed vegetated 25 foot -wide buffer except where specific
disturbance is permitted. A wetland delineation report was prepared and
submitted to the USACE on November 16, 2005.
Stream Description: Ten named blue line streams and fifteen intermittent
streams were identified on the USGS topographic quadrangles throughout the
site. Field investigation revealed these numbers to substantially underestimate
the roughly 350 intermittent and perennial streams that exist on the property.
Approximately 64 miles of stream channels were identified and mapped on
Laurelmor (Figures 7a -7j). The site is comprised of numerous headwater basins
with intricate dendritic drainage patterns formed as a result of underlying geology
and subsequent erosion. In general, the property drains toward the southeast.
The northern portion of the tract drains into South Fork Laurel Creek. Laurel
Creek confluences with Elk Creek near the eastern boundary of the property.
Several tributaries drain the eastern section of the tract directly into Elk Creek.
Dugger Creek drains a large portion of the tract's interior. The southwest region
of the site drains into Little Dugger. Little Dugger Creek flows into Dugger Creek
at the southern boundary of the property. Dugger Creek flows into Elk Creek
approximately 1 -mile below the property. NC DWQ has classified all streams
fore mentioned and named tributaries, including Swift Ford, Flat Branch, Pine
Knob, Long Cove, and Puncheon Cove, as Trout Waters and Outstanding
Resource Waters. A small area of the property to the west of Little Dugger
Mountain forms the headwaters of Tony's Branch. Horton Branch drains
approximately 350 -acres of the project area. Both Horton and Tony's Branch,
classified by DWQ as Trout Waters, flow into Joe's Creek and eventually into the
Yadkin River. All streams are well shaded with a mix of hardwood and conifer
trees and shrubs and often a dense understory of rhododendron.
Laurelmor 404/401 Page 13 of 94 2/1/2006

Project Narrative
Table 1. Stream Drainage Data
Totals 6050 337,200 63.9
Wetland Description- There were a total of 8.27 -acres of jurisdictional wetlands
delineated within Laurelmor. The identified wetlands were in general restricted to
narrow strips and small benches along the stream corridors. There are three
distinct types of wetlands identified on the site:
1 . Riparian Forest Wetlands- Dispersed throughout the project area are sections
of valley containing pockets of riparian and abandoned side channel
wetlands. Fluctuating stream levels, ground water discharge, and direct
surface runoff typically influence the hydrology and ground water table within
the moderate to low-grade or depressional areas. Dryer habitat types are
often embedded within the riparian wetlands on slightly higher landforms (i.e.
spur ridge) and usually transition out of wetland areas with abrupt topographic
breaks. Due to the high gradient of the streams, these areas are scattered
and non-contiguous and seldom extend beyond the 25 -foot trout buffer
required by the State for a designated trout stream tributary.
2. High Elevation Seep Wetlands- The underlying geology of the site creates
conditions that influence and sustain numerous seeps and springs at the
head of streams and along stream channels. These seeps are generally
associated with channels and seldom occur as isolated pockets along the
valley side slopes.
Laurelmor 404/401 Page 14 of 94 2/1/2006
Stream Length
Drainage Basin
(approx.)
System
Symbol
Approximate Acres Feet
Miles
1 Dugger Creek
DU
1650
75,900
14.40
2 Laurel Creek
LA
800
56,760
10.75
3 Little Dugger
LD
415
34,980
6.63
4 Swift Ford
SF
480
25,080
4.75
5 Horton Branch
HB
350
20,460
3.88
6 South Dugger
SD
220
19,800
3.75
7 Flat Branch
FB
370
17,160
3.25
8 Puncheon Cove
PC
360
15,840
3
9 Elk Creek Tribs
Elk
320
13,860
2.63
10 Pasley Cove
PS
200
11,880
2.25
11 Upper Laurel
UL
160
11,220
2.13
12 West Dugger
WD
160
9,900
1.88
13 Long Cove
LC
160
8,580
1.63
14 Mouth of Laurel
LAM
130
6,600
1.25
15 Pine Knob
PK
110
4,620
0.88
16 Tony's Branch
TB
150
3,960
0.75
17 -Joe's Creek UT
ic
15
600
0.11
Totals 6050 337,200 63.9
Wetland Description- There were a total of 8.27 -acres of jurisdictional wetlands
delineated within Laurelmor. The identified wetlands were in general restricted to
narrow strips and small benches along the stream corridors. There are three
distinct types of wetlands identified on the site:
1 . Riparian Forest Wetlands- Dispersed throughout the project area are sections
of valley containing pockets of riparian and abandoned side channel
wetlands. Fluctuating stream levels, ground water discharge, and direct
surface runoff typically influence the hydrology and ground water table within
the moderate to low-grade or depressional areas. Dryer habitat types are
often embedded within the riparian wetlands on slightly higher landforms (i.e.
spur ridge) and usually transition out of wetland areas with abrupt topographic
breaks. Due to the high gradient of the streams, these areas are scattered
and non-contiguous and seldom extend beyond the 25 -foot trout buffer
required by the State for a designated trout stream tributary.
2. High Elevation Seep Wetlands- The underlying geology of the site creates
conditions that influence and sustain numerous seeps and springs at the
head of streams and along stream channels. These seeps are generally
associated with channels and seldom occur as isolated pockets along the
valley side slopes.
Laurelmor 404/401 Page 14 of 94 2/1/2006

Project Narrative
3. High Elevation Wet Meadow- A unique wetland for the subject site is located
near the head of a significant tributary (SD -F) to Dugger Creek at an
approximate elevation of 2030 feet. This wetland (SD -BOG) is formed by
multiple seeps with substantial discharge into a broad valley area of
moderately low-grade along a relative high -elevation shelf. A braided and
sinuous perennial stream dissects this wetland, creating an intricate drainage
network across the surface. Continually inundated and/or saturated
conditions, in general, restrict woody vegetation development throughout the
wetland, although some scattered shrubs have developed on slightly higher
pockets. This area is approximately 0.36 -acres is size and differs slightly
from the riparian wetland typical throughout the site by having fewer shrubs
and trees, which has allowed for the establishment of a more diverse
herbaceous community.
Proposed Impacts to Jurisdictional Waters:
After avoidance and minimization, permanent impacts to Waters of the United
States are limited to eleven (11) locations within the project area (Figures 1 Oa -
101)). All the projected impacts are associated with the construction of two
proposed 18 -hole championship golf courses. There are five proposed
impoundments and six areas where portions of small intermittent streams are
proposed to be french drained. The impacts will consist of inundation and filling
of waters of the US, including perennial streams, intermittent streams and
wetlands for the purpose of constructing dams and creating five impoundments
and for the grading and construction of five golf holes and the proposed driving
range. Total impacts from the proposed activity are limited to 0.18 acres of
wetland impact and 6331 linear feet of stream impact. The stream impact is
divided into 4413 linear feet of impact to perennial streams and 1918 linear feet
of impacts to intermittent streams. Impacts are further divided into those
associated with french draining or filling and those impacts associated with
inundation of undisturbed streams or wetlands. These impacts are summarized
in Table 2,
Utility Line Impacts: There will be 25 locations where utility lines, primarily
sewer lines, will cross jurisdictional Waters of the US. All of these crossings will
involve temporary impacts to streams that will impact less than 25 linear feet of
streambed and will be restored immediately following the installation of the pipe.
The maximum amount of temporary impacts to Waters associated with utility line
crossings will be 625 linear feet. The locations of these temporary impacts are
shown in (Figures 11 a-1 1 d). The restoration of the temporary impacts will involve
the replacement of natural substrate material and the restoration of previous
channel gradient. Photos of typical utility crossing restorations are provided in
Appendix C.
Golf Cart Path Bridges: As with any golf course, an integral part of the course
design is the golf cart paths. Both courses at Laurelmor will include cart paths
designed to transport players safely from hole to hole. The paths are also
Laurelmor 404/401 Page 15 of 94 2/1/2006

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Laurelmor 404/401 Page 16 of 94 2/l/2006

Project Narrative
designed to add to the overall appeal of the course by remaining out of sight on
some holes and incorporating elaborate bridges and stonewall in other areas.
There will be no impacts to jurisdictional Waters of the US associated with the
golf cart paths. There will be numerous stream crossings but all will be bridged
such that no fill or structures will be placed in waters of the US. Photos of typical
golf cart bridges are included in Appendix C.
Road Crossings: The road network for Laurelmor will consist of approximately
50 miles of county standard subdivision road with pavement widths of either 20
feet (Parkway) or 18 feet (collector system). The road network is being designed
with grass lined (reinforced with geotextile matting) ditches and vegetated
shoulders. There will be no curb and gutter used on this project. There will be 24
bridged stream crossings. All of these will be designed such that there will be no
impact to jurisdictional Waters of the US associated with these crossings. The
locations of these crossings are shown on Figure 12 and Table 3 provides
stream bankfull width (jurisdictional area width) and proposed bridge length at
each crossing location.
Floodplain Impacts: The only mapped Flood Hazard Areas within the project
site occur along Elk Creek and associated backwater areas in the southeastern
boundary areas of the site. No activities are anticipated in Special Flood Hazard
Areas that will require a flood study or Floodplain Development Permits from the
local government.
Project Planning:
Laurelmor will encompass approximately 6050 acres and will involve the
construction of major bridges, two golf courses, well over 1000 residential units,
approximately 50 miles of roads and numerous other features. This application
is for permanent impacts to 6331 linear feet of streams and to 0.18 acres of
jurisdictional wetlands. It is strongly emphasized that these quantities represent
the total for the entire site and project, out of approximately 337,200 linear feet of
stream and 8.27 acres of wetlands. A master plan has been completed for this
project. To date tremendous resources have been expended towards road, lot
and infrastructure planning. This site has been extensively evaluated for the
presence of jurisdictional streams and wetlands, Threatened and Endangered
Species, and significant cultural resources. Where design problems have been
encountered, additional properties have been acquired in order to have good site
access and a safe road network. Project resources that have already been
allocated to erosion control efforts including installation, maintenance and
inspection are truly above and beyond that typically encountered on development
projects. The developers of Laurelmor are strongly committed to being proactive
with regard to regulatory and environmental compliance.
The development concept used for this project is to confine the majority of the
development infrastructure to ridge tops and upper slope areas leaving the
stream corridors and lower slopes largely undeveloped. The road network is laid
out such that all major travel corridors are on ridges. There are several locations
Laurelmor 404/401 Page 17 of 94 2/1/2006

Project Narrative
where, in order to prevent long dead-end spurs, a road crossing over a stream
was required to create a loop. There were additional areas where topographic
constraints prevented roads from being designed at the top of drainage systems
and a mid -slope bench was found to be a better location for the road. Altogether,
in approximately 50 miles of proposed roads, there are 23 proposed road
crossings over jurisdictional streams. All such crossings will be bridged with no
impacts to Waters of the US (Table 3). These crossings are considered
necessary for safety and for overall project quality.
Table 3. Proposed Stream Crossings via Bridges
All streams and wetlands on the site have been delineated and mapped and all
stream corridors will be buffered. A wetland delineation report was prepared and
submitted to the USACE on November 16, 2005. The lot layout on the site has
Laurelmor 404/401 Page 18 of 94 2/1/2006
Total
Minimim
Bankfull
Riparian
Jurisdictional
Bridge
Bridge
Stream
Width (ft)
Width (ft)
Width (ft)
Span (ft)
1
HB -B
4
2
6
18
2
HB -D
8
4
12
22
3
HB -E
4
0
4
16
4
HB -F
6
2
8
20
5
UL -1
8
3
11
20
6
LA -9
5
0
5
16
7
LA-8A&C
11
5
16
24
8
LA -71E
6
0
6
18
9
LA -7C
5
4
9
20
10
LA -7A
3
3
6
18
11
LA -41E
7
2
9
20
12
LA -41D
5
3
8
18
13
FB -8B
3
3
6
18
14
LAM -1 B
4
0
4
16
15
SF -37
8
6
14
26
16
DU -AB
10
2
12
24
17
DU -AC
3
2
5
16
18
SD-W4A
6
10
16
30
19
DU -A
5
5
10
20
20
SID
20
5
25
40
21
LD -P
5
25
30
42
22
DU -25G
4
4
8
20
23
DU -25A
5
2
7
20
24
WD -F
4
0
4
16
All streams and wetlands on the site have been delineated and mapped and all
stream corridors will be buffered. A wetland delineation report was prepared and
submitted to the USACE on November 16, 2005. The lot layout on the site has
Laurelmor 404/401 Page 18 of 94 2/1/2006

Project Narrative
been and will continue to be designed such that no streams or buffers will be
included within any residential lots. All streams, wetlands and buffers will remain
in the control of the Applicant and will be held in common area or conservation
easements (held by a local land trust) and permanently protected.
Laurelmor will be a low-density development. Total impervious area for the
development will be substantially less than the 12% maximum allowed in areas
designated as ORW. The expected final impervious area will be closer to 9%
(Table 4).
Table 4. Estimated Impervious Coverage at Maximum Build -out
Item
Unit of Measure
Quantity 1
Quantity 2
Total Area
20 -foot roads
linear feet
20
200,000
4,000,000
sq ft
18 -foot roads
linear feet
18
75,000
1,350,000
sq ft
12 -foot private drives
linear feet
12
6,000
72,000
sq ft
Other road areas
sq feet
1
65,000
65,000
sq ft
Core hotel
acres
30
43,560
1,306,800
sq ft
Golf course cart paths
linear feet
8
70,000
560,000
sq ft
Single family residences
each
1200
10,000
12,000,000
sq ft
Multi family units
each
650
3,500
2,275,000
sq ft
Equestrian center
acres
3
43,560
130,680
sq ft
Vineyards
acres
2
43,560
87,120
sq ft
Employee parking
perspace
1000
400
400,000
sq ft
VWVTP
each
1
100,000
100,000
sq ft
VVW pump stations
each
60
5,000
300,000
sq ft
Water facilities
each
16
8,000
128,000
sq ft
Golf club house
acres
5
43,560
217,800
sq ft
Water park
acres
3
43,560
130,680
sq ft
Golf maintenance
acres
4
43,560
174,240
sq ft
Road/utility maintenance
acres
4
43,560
174,240
sq ft
Pack of house
acres
6
43,560
261,360
sq ft
Total Impervious
Total Impervious
Total Site
-Percent Impervious
23,732,920
545
6,050
9.01
sq ft
acres
acres
-percent
Conservation Plan:
Early in the project development phase of Laurelmor, E'nV Inc. was charged with
the creation of a comprehensive conservation plan for the entire project area.
Initial contacts were made with local land trusts and an agreement was reached
with the Blue Ridge Rural Land Trust to hold conservation easements over much
of the open land within the development. The development of this plan has
involved consideration of numerous factors including the assessments of streams
and wetlands on the site, a natural resource habitat assessment, a cultural
resource site assessment, and consideration of the site as a significant corridor
for migratory birds and butterflies. The plan has also had to consider the
proposed development and identify areas that are not available for conservation.
The resulting plan currently includes suitable areas in excess of 1000 acres
miles
37.88
14.20
1.14
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Project Narrative
encompassing over 60 miles of riparian corridor (Figure 13). This plan will
continue to evolve as residential lots are final platted and precise easement
boundaries can be determined. We expect that ultimately over 2000 acres of the
project will be placed into permanent conservation easements. There will be an
extensive pedestrian trail network through this area and a more limited network
of equestrian trails. While this trail network has not been designed all necessary
stream crossings will be bridged such that there will be no impacts to
jurisdictional Waters of the US.
Golf Course Design Process:
From the outset of this project a primary goal has been to avoid and minimize
impacts to sensitive environmental areas including jurisdictional Waters of the
US. A full delineation of all jurisdictional Waters of the US was performed in the
early stages of project planning and development. The Applicant also initiated
phase one site assessments for both Threatened and Endangered Species and
significant cultural resources. Results of these studies were used as they
became available to guide planners in designing around sensitive areas
throughout the site.
The two proposed golf courses involve the largest concentration of land
disturbing activity and consequently posed the greatest challenge to avoid and
minimize impacts to Waters of the US. When the Applicant initially purchased the
property (5600 acres) there was a permitted project associated with a 1200 -acre
portion of the tract. This project (Heavenly Mountain Resort (HMR) Golf Course)
was permitted on November 24, 2003 under the name of Kaplan Holdings LLC
with Action ID- 200330353. The Applicant decided not to construct the previously
permitted course primarily because of the almost 1100 linear feet of required
stream relocations and a large amount of additional steep slope grading in close
proximity to streams that would have left the golf course with a forced
appearance and not allowed for the natural beauty of the site to be fully featured.
An additional drawback of the initial golf course design was that it lacked
significant water features-, these water features are critical to irrigation, fire safety
and playability of the courses.
The proposed golf courses are designed primarily as ridge top courses in
contrast to the HMR course, which was primarily a valley course. The change to
a ridge top course was made possible by having more land to work with, 6050
acres verses 1200 acres and a difference in development philosophy. Typical
golf course developments place a strong emphasis on maximizing the number of
"prime" lots adjacent to the golf course with views both to and from the golf
course. The current golf course concept de-emphasizes the premium on adjacent
lots and allows the ridge top areas to be used for golf course instead of lots.
There are some portions of the two golf courses that are adjacent to lots but an
examination of the course layout reveals that this was not a governing principle in
designing the layout.
Laurelmor 404/401 Page 20 of 94 2/1/2006

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The challenges in laying out a high quality golf course are immense. Each course
needs to meet specific length requirements, needs a balance and comfortable
mix of par 3, par 4, and par 5 holes, and needs to blend aesthetically with the
topography and natural environment, and incorporate some of these natural
features as hazards. There needs to be a flow that begins and ends in the same
general area, and each golf hole must be both playable and aesthetically
pleasing. When these design challenges are combined with the even more
critical goal of minimizing impacts to jurisdictional Waters of the US, the task
becomes especially difficult. In the case of the Laurelmor project, golf course
designers explored numerous layouts, including multiple attempts to modify the
previously permitted Heavenly Mountain Resort course layout, before settling on
the current location. The proposed course #1 layout basically plays along ridges
and across stream valleys. In most cases playing across stream valleys allows
for the stream corridor and riparian buffer to be left intact with only a selective
cutting impact to the buffer associated with removal of the tall trees that would
create a barrier to play. The proposed course #2 layout is also primarily along
ridges and across valleys with a few holes planned along the lower shoulders
and high terraces near Dugger Creek. There are no proposed impacts to the
main stem of Dugger Creek.
The advantages of the ridge top layout approach for both proposed golf courses
is evident when considering that total impacts related to grading, on both
courses, excluding the driving range, will be only 1115 linear feet of small
intermittent streams and no wetland impact. While no impact to jurisdictional
Waters is considered insignificant, this number represents a major effort at
avoidance and minimization when considering the amount of grading that will
occur in the process of constructing two complete golf courses.
While the ridge top golf course layout allows for a more desirable course it lacks
any water features and will require significant quantities of irrigation water. The
proposed lakes will serve as water features, considered essential, for several golf
holes on both proposed courses, and will provide a valuable source of irrigation
water. It should also be noted that these proposed lakes will be vital components
of the on-site and regional fire fighting infrastructure. As was pointed out in the
letter from District Forest Ranger Birckhead, "the construction of lakes will assist
us greatly in being able to utilize our helicopters in getting water quickly to
needed areas." He added, "The larger the lake and the amount of water it
contains, the better off the community will be. It would be great if you have the
opportunity to construct other lakes on the property as well".
All proposed lakes will be designed with a cold water discharge structure or
bottom draw -off device. The installation of a bottom draw -off device helps reduce
the temperature of water released by the pond to receiving streams by siphoning
off the cooler water found near the pond bottom.
Laurelmor 404/401 Page 21 of 94 2/1/2006

Project Narrative
Water Quality Issues:
Stream Classification and Buffers: All streams within the project site are
designated as Class C, Trout, Outstanding Resource Water (ORW), with the
exception of the Horton Branch drainage area, which is designated Class C,
Trout. The Trout stream designation invokes a mandatory 25 -foot undisturbed,
naturally vegetated buffer on each side of all designated perennial streams and
all perennial tributaries of such streams. The ORW designation invokes a
mandatory 30 -foot vegetated buffer on each side of all designated streams and
tributaries of designated streams. Throughout the Laurelmor project all streams
will have a vegetated 30 -foot buffer on each side of the top of bank. The only
exceptions to this will be in the area of the golf courses where at specific
locations buffers will be reduced along intermittent streams.
Stormwater Management:
Stormwater management plans, reports and calculations will be an integral part
of the construction plans and documents for the Laurelmor project. Storm
drainage and erosion control design will be a critical component of golf course
construction plans and will be given utmost consideration. All stormwater
management facilities will be designed for a minimum 25 -year post construction
runoff rate. The majority of the stormwater will be routed through grassed swales
(roads and golf courses) to drainage structures or pipes. The drainage pipes will
discharge to either a rip -rap plunge pool (roads) or a bioretention area (golf
courses). The resort area, clubhouse and condominium areas will discharge into
detention/retention systems before being discharged at a pre -construction runoff
rate. Single-family houses will discharge roof drainage into gravel infiltration
systems at individual locations. These measures will insure a minimum impact on
the surrounding slopes and streams.
At a minimum the following stormwater management standards will be followed:
1 . All stormwater from tees, greens and fairways will be directed to the
permanent stormwater management facilities (stormwater wetlands, bio -
retention areas, wet ponds, sand filters, grassy swales, or level spreaders)
designed and constructed in accordance with the ND DWQ Stromwater
BMP Design Manual. All stormwater management facilities will be
designed to protect water quality by controlling suspended pollutants,
dissolved pollutants, temperature, and discharge quantity.
2. The stormwater management plan will include a written Operation and
Maintenance Agreement, approved by the DWQ, to treat runoff from the
clubhouse, core multi -family area, and other high-density amenity areas.
No permanent facilities on the site for which stormwater management
structures are specified in the approved plan will be occupied until the
SWM measures are constructed and operational. The structural
stormwater practices approved by DWQ and implemented on site will be
constructed according to the plan and maintained in perpetuity
Laurelmor 404/401 Page 22 of 94 2/1/2006

Project Narrative
Waste Water Treatment and Disposal:
The wastewater treatment and disposal system will consist of a piped collection
network of over 55 miles in length. Numerous pump stations are located
throughout the system to allow a large portion of the overall system to be placed
in the proposed road right-of-way. This system includes several million gallons of
tank storage sufficient to hold a 30 -day peak volume. The treatment facility has
been designed and permitted for treating the effluent to reuse standards. There
are two modes of disposal permitted with this system. The first is a spray
irrigation system for use on the golf course tees, greens and fairways. The
second is a drip irrigation system that disperses the effluent through
approximately 170,000 linear feet of small diameter line and thousands of drip
emitters over approximately 120 acres of undeveloped forested land. This
system is considers far superior to conventional septic systems on a
development such as this as there will be no direct discharges of treated waste
water to any streams or wetlands.
Water Supply System:
The water system will consist of community wells and a distribution system to
serve the entire development. This will be a pressurized system designed to
serve the resort/clubhouse area, all residential areas, and fire supply. This
system will be designed in accordance with NC DEH regulations.
Sediment and Erosion Control:
The Applicant recognizes that erosion and sedimentation control efforts above
and beyond the minimum requirements are essential to the viability and future
success of this project. Extensive resources have already been expended on
erosion control with portions of this project not involving jurisdictional Waters of
the US. The vast majority of the site lies within watersheds designated as ORW
and to date all construction activities have been phased such that no more than
20 acres have been disturbed at any time. All activities over the past year have
been regularly inspected through the Winston Salem regional office of the
NCDENR DLR, the Applicant has not received a single notice of violation despite
several periods of extreme rainfall during the summer of 2005. Due to the size of
this project, the demonstrated success of on-site erosion control contractor, and
the separate nature of various project elements, the Applicant has applied for a
waiver of the 20 -acre disturbed area limit-, the Division of Land Resources is
currently considering this request. The following is a list of activities and
resources currently dedicated to erosion control efforts on the site'.
1 . We already have on site a crew of ten personnel with a supervisor
that are dedicated full time to installing and maintaining erosion control
measures for the road construction portion of the project. Their skill in
maintaining appropriate measures on a large-scale project is reflected in
the positive inspection reports received by DLQ staff to date. The crew
also has three 3,000 -gallon hydro -seeders on-site that are being used on
an as needed basis to stabilize disturbed land immediately. The project
Laurelmor 404/401 Page 23 of 94 2/1/2006

Project Narrative
also has three (4) rain gauges scattered across the site and NPDES
records are being maintained on a daily basis.
2. The Ginn Golf Co. (a subsidiary of The Ginn Companies) will
implement the same level of care to assure compliance with the
regulations. It will have a similar, separate erosion control crew dedicated
to the golf course construction. Ginn Golf has also hired a Golf Course
Construction Manager with 20 years of experience of building golf courses
in the mountains of North Carolina. He is currently on-site.
3. The golf course erosion control measures will utilize temporary
sediment traps for less than 1 -acre drainage areas and temporary
sediment basins with skimmers for larger drainage areas. The basins with
skimmers are fully sized for the disturbed area and are not "down -sized"
as allowed by the regulations. Silt bags will be installed at the skimmer
basin pipe outlets. Two (2) rows of bio -logs will be installed at the
downstream area of all sediment basins. The temporary sediment basins
at permanent drainage pipe outlets will be converted into either bio -
retention cells or pocket wetlands depending on drainage area. All
erosion control measures will be designed for a 25 -year storm event. An
Erosion Control Manual has been developed by McGill Associates for the
project that contains measures specifically designed to address the unique
problems encountered in mountainous terrain. This document also
specifies personnel and equipment to be maintained on site.
4. Ginn has assembled an experienced management team dedicated
to ensuring that the project stays in compliance with applicable
requirements. The project has bi-weekly team meetings attended by Ginn
personnel, contractors, consultants, and design professionals. The team
meetings are designed for all the project issues to be discussed and
addressed in a written format. In addition to the team meetings, the
project manager visits the site on a weekly basis. McGill Associates
Construction Observation personnel make site visits at least three (3) days
week, and often on a daily basis. The project Geotechnical Engineers are
at the site weekly and their technicians are at the site daily. Ginn
personnel inspect the erosion control measures on a daily basis.
Everybody involved on the project has been directed to point out any
erosion control issues on the site and has the authority to shutdown
grading operations until the appropriate measures are implemented. This
same level of diligence will continue as the golf course construction gets
under way.
5. A project wide program of precipitation and turbidity monitoring has
been underway on the site for most of the past year. This program was
initiated in response to a condition of the previously issued permit for this
project. Data collected to date indicates storm event turbidity levels in
undisturbed streams ranges between 12 and 33 ntu's depending upon
storm intensity, duration and other factors. This program will continue, as
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Project Narrative
well as a planned program to monitor stream stability below proposed
impact areas. Precipitation and temperature is monitored at 4 locations
across the project site. Multiple stations were installed to analyze variation
across the site due to elevation and orientation.
6. The Applicant has initiated a soils study performed by the project
Geotechnical Engineer to determine the appropriate flocculent to use for
the various soil types found on site. Based on the results of this study,
guidelines will be established to dictate when and where flocculants may
be used. Flocculants will be kept on site and used in accordance with the
guidelines as necessary to help keep turbidity levels low in receiving water
bodies.
Cultural Resources:
The Applicant contracted with Archaeological Consultants of the Carolinas, Inc.
(ACC), to conduct a cultural resources survey of the Dugger Creek tract in
southeastern Watauga County and northwestern Wilkes County, North Carolina.
This project was coordinated through E'nV Environmental Consultants. The
tasks included in this investigation were review of archival data and historic maps
relevant to possible resources situated in the tract and conducting a pedestrian
survey of select portions of the tract determined to have high potential to contain
cultural resources to identify cultural resources in the project tract.
The project tract is located approximately 7.0 miles (11.26 km) southeast of
Boone, North Carolina. It consists of steeply sloping mountains and various
creeks. The borders of the tract are roughly outlined by a series of creeks-, the
northern border follows South Fork Laurel Creek, the western border follows
Joes Creek, the southern border follows Little Dugger Creek, and the eastern
border follows Laurel Creek. The survey areas defined during a cultural
resources reconnaissance of the tract include over 213 acres of ridge tops and
saddles.
The earlier field reconnaissance of the Dugger Creek tract identified two
prehistoric sites and one historic site. During the course of this survey, those
sites were relocated and documented. In addition, an abandoned mineshaft
found on the site was located and documented during this survey.
Archival research was conducted at the Office of State Archaeology and at the
Division of Survey and Planning, both in Raleigh, North Carolina. This research
was comprised of a review of all records on file regarding previously recorded
cultural resources within the project tract and in its immediate vicinity. Historic
maps of the vicinity were also consulted, as were county soil maps. No
archaeological sites or historic resources have been recorded within the Dugger
Creek tract or in its vicinity prior to this investigation.
For the survey, more in-depth examination of historic maps of the project tract
was conducted. In addition, local residents were interviewed. Ms. Clemmie
Watson, Ms. Bernice Watson, and Mr. Tommy Watson provided valuable
Laurelmor 404/401 Page 25 of 94 2/1/2006

Project Narrative
information on the project tract. Clemmie and Bernice were born on the project
tract and helped identify aspects of several of the historic sites. They had lived in
a house within the project boundaries for many years. The Watsons provided
several photographs showing elements of the fire tower and one of the historic
house sites. Also, family members worked at the fire tower and they provided a
photograph of the fire tower.
Pedestrian and vehicular investigation of portions of the Dugger Creek tract was
conducted in November and December 2005. The survey focused on ridge tops
and saddles, but also included a number of drainage heads and selected
portions of creek flood plains.
As noted above, three archaeological sites were identified during the tract
reconnaissance. An additional eight sites were identified during the survey.
These 11 sites are summarized in Table 5. Each identified site was defined
through short interval shovel testing and was evaluated for its National Register
of Historic Places (NRHP) eligibility. To be eligible for the NRHP, a site must
retain spatial integrity of deposits and have the potential to provide information
relevant to regional or local research questions.
An intensive archaeological survey was conducted in the Dugger Creek tract.
The tract has undergone severe erosion on high ground and logging roads have
impacted much of the level ground along the ridge spines. There are numerous
rock outcrops and slides in drainages. The prehistoric sites identified during
these investigations have been severely disturbed by erosion and land modifying
activities. The historic sites have been impacted by the destruction of the
structures, where present, and general decline in integrity over time. For these
reasons, none of these sites are considered to meet NRHP eligibility criteria.
Table 5. Summary of Resources Identified in the Duaaer Creek Tract.
Field Site
Designation
Site Description
NRHP Eligibility
Site 1
Prehistoric lithic scatter
Ineligible
Site 2
Historic House Site -Watson Family Home
Ineligible
Site 3
Prehistoric Lithic Scatter
Ineligible
Site 4
Historic mine shafts
Ineligible
Site 5
Prehistoric Lithic Scatter
Ineligible
Site 6
Dugger Creek Fire Tower
Ineligible
Site 7
Jasper Watson Home Site
Ineligible
Site 8
Prehistoric Lithic Scatter
Ineligible
Site 9
Possible Still Remains
Ineligible
Site 10
Possible Still Remains
Ineligible
Site 11
Prehistoric Lithic Scatter
Ineligible
Laurelmor 404/401 Page 26 of 94 2/1/2006

Project Narrative
The investigations of the Dugger Mountain tract provide important information on
mountain settlement from prehistory through the twentieth century. As such, this
project will be a valuable contribution to our knowledge and understanding of the
area despite the overall poor quality of the sites identified.
Threatened and Endangered Species:
Baystate Environmental Consultants, Inc. (BEC) performed a phase -one
Threatened and Endangered species survey and Habitat Assessment (TEHA) for
the project site during the fall of 2005. The current evaluation summarizes our
findings relative to the federally listed Threatened, Endangered and "of concern"
species that may potentially occur on the site. As part of the study, detailed, but
localized, field surveys were used to ground -truth habitats observed in the high-
resolution aerial photographs of the entire site. Survey locations were geo-
referenced during survey using handheld GPS.
The project area is located on the eastern escarpment of the Blue Ridge covering
an area of greater than 6000 acres from a base elevation of 1350 feet in
southwestern Wilkes County to 3950 feet in eastern Watauga County. Forests
cover approximately 95 to 99% of the 6000+ -acre Ginn property. An elevation
change of 2600 feet occurs from mountain peaks on the western end to lower
reaches of Elk and Dugger Creeks on the southeastern end of the project site.
The property lies within the sub -watersheds of two major headwater streams of
the Yadkin River Basin-, Buffalo Creek and Elk Creek. These creeks lie upstream
of Kerr Scott Reservoir, which acts as a barrier to movement of aquatic species.
A portion of the main channel of Elk Creek runs adjacent to the Property on its
east side, with three of its tributaries originating on the Property-, Dugger / Little
Dugger Creeks, South Fork Laurel Creek, and Swift Ford Branch.
The Ginn property was surveyed for species Federally listed as Endangered,
Threatened, and Of Concern, as well as their habitats, between October 3 and
28, 2005. The BEC survey team conducted two types of resource surveys. First,
a general survey of the property was conducted to assess habitat property -wide
and prepare a map of habitat cover types. Second, focused surveys, to assess
habitat quality and look for listed species, were conducted using spot survey
methods in development tracts and in sensitive habitat areas. Locations for
these focused surveys were provided in part by ENV Environmental (John Vilas
and Brian Sandefur) due to their knowledge of the property from past wetland
and survey work. Additional survey locations were selected by the BEC team,
based on the likelihood for presence of high quality habitat.
In total, 24 species of plants (14) and animals (10) that are listed as
"Threatened," "Endangered," or of "Special Concern," were determined to have
either known occurrence at the Ginn project site or potential presence based
upon habitat types present. Of these, only three have actually been observed,
with two species occurring in Element Occurrence records and one species
being observed by sign during the course of this study. None of these three
Laurelmor 404/401 Page 27 of 94 2/1/2006

Project Narrative
species are "Threatened" or "Endangered." All but two of the twenty-four species
are presently listed at the "Special Concern" status level, which is not regulated.
Only two of the species are regulated at the status of "Threatened." These are
the bog turtle and the dwarf flowered heartleaf, again neither of which have been
observed at the site.
Seven potential vertebrate species included one reptile (bog turtle), two birds
(Cerulean warbler, yellow -bellied sapsucker), and 4 mammals (Alleghany wood
rat, eastern small footed bat, northern water shrew, and Appalachian cottontail).
All are listed as "Special Concern" level of protection except the bog turtle, which
is considered at "Threatened" status. Only the bird species and the Alleghany
wood rat have actually been observed on site, with the warbler and wood rat
being identified in the Element Occurrence records and the sapsucker was
observed by sign in this current study.
Four invertebrate species are indicated as potentially present on site, all based
upon the habitat types present and their occurrence within the region. These
species are all insects in the dragonfly and butterfly classes. All of the species
are presently listed at "Special Concern" status level.
There are fourteen species of listed plants potentially present on site based upon
habitat types present. Ten of these plants are vascular plants and three are non-
vascular plants. Nine of the plants are presently listed at "Special Concern"
status level, but the Dwarf Flowered Heartleaf is listed as "Threatened".
With respect to the bog turtle and the dwarf flowered heartleaf, each of the
observed potential habitat areas for these species will be included in those areas
subject to the conservation easements noted above.
Lake Dam Safety Permits:
In addition to permits applied herein from the US Army Corps of Engineers and
the NCDENR Division of Water Quality, permitting will be required from the
NCDENR Land Quality Section. First, an erosion and sedimentation plan must
be submitted for the project. This permit will cover several key areas-, protection
of the streambed during clearing and grubbing of the lake impoundment area,
protection during construction of the dam, and protection of the stream below the
dam.
In addition, construction of the dam will require review and approval by the Dam
Safety Office of the Land Quality Section. Assuming that the dams constructed
for the project will be considered high hazard structures, the review will include
the following-, a stability analysis of the site including complete geological and
geotechnical study of the dam foundation and earthen materials, a complete
hydraulic design for the primary spillway, secondary (emergency) spillway, cold
water return during low stream flows, drain valve and system, seepage flow
study, provisions for minimum downstream flows, as well as dam construction
and lake filling schedule.
Laurelmor 404/401 Page 28 of 94 2/1/2006

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Page 63 of 94
2/l/2006

Avoidance, Minimization, and Mitigation
LAURELMOR PROJECT
Avoidance, Minimization, and Mitigation Narrative:
A thorough jurisdictional delineation (Figures 7a -7j) revealed that approximately
64 miles (337,200 linear feet) of jurisdictional streams and 8.27 acres of wetlands
are located throughout the project site. The mission given to the project design
team was to avoid environmental impacts to these and other features to the
maximum extent practicable. The result is, despite its scope and the prevalence
of jurisdictional waters, the project's total impacts are limited to 6331 linear feet of
streams and 0. 18 acres of wetlands.
The project purpose is the development of Laurelmor into a low density, world-
class resort community and associated amenities. To implement this purpose,
the Applicant has evaluated and reevaluated its plans to identify and implement,
where practicable, upland alternatives that do not involve discharges to waters of
the United States. This effort has resulted in the proposed impacts being limited
to the construction of the two proposed 18 -hole championship golf courses. With
respect to the courses, there are five proposed impoundments and six areas
where portions of small intermittent streams are proposed to be french drained
(Figure 14). As described below, the impoundments are critical to achieving the
project purpose and are water dependent in that they are a necessary auxiliary
water supply for irrigation and fire protection, and also serve as features for the
championship golf courses. There are no practicable upland alternatives to
serving these needs of the project.
The proposed project meets the requirements of, and mitigation sequencing
imposed by, the Section 404(b)(1) guidelines and applicable guidance. The
Applicant has achieved avoidance and minimization to the point where
anticipated impacts are relatively minor and are the minimum necessary to
achieve the project purpose. The end result is that the Applicant is confident that
there are no practicable alternatives that could be implemented without any
impact to waters of the United States, and that the project proposed in this
application represents the least environmental damaging practicable alternative.
The project complies with the Guidelines in the following ways:
1. Avoidance through reduction of Promect density — The Applicant has
intentionally kept the project density to a low level in an effort to maintain the
pristine character of the site, preserve the natural beauty, protect natural
resources, preserve water quality, and to create a unique resort product that
combines luxury and world class amenities with a strong emphasis on
environmental stewardship. The proposed project density is one dwelling unit per
4.6 acres on average. Adding the open space to the single-family residential area
generates this figure. The maximum density allowed by county regulations would
be one dwelling unit per every half acre. At that density, 12,000 single-family
residential units would be allowed. While this level of development would clearly
not be feasible given the topography and other practical and regulatory
Laurelmor 404/401 Page 64 of 94 2/1/2006

Avoidance, Minimization, and Mitigation
constraints of the site, a development plan that included 5000 single-family lots
and 80 miles of roads would be feasible under existing site constraints and
regulatory guidelines. Such a development scenario would have significantly
more impact on the natural resources of the site than the proposed development
scenario. Also, this scenario would not leave large unbroken riparian corridors
and open spaces, and would likely have much more significant impacts on water
quality. The proposed low-density project has instead resulted in the minimal
impacts outlined in this application.
2. Avoidance of impact through promect design, -- Prior to any final
designs extensive site delineation was performed to identify all jurisdictional
streams and wetlands located on the site. The site structures and amenities
were then planned to avoid impacts to the maximum extent practicable.
The Applicant's development concept is to confine the majority of the
development infrastructure to ridge tops and upper slope areas leaving the
stream corridors and lower slopes largely undeveloped. The road network is laid
out such that all major travel corridors are on ridges. There are several locations
where, to prevent long dead-end spurs, a loop is required and a stream crossing
is unavoidable. There were additional areas where topographic constraints
prevented roads from being designed at the top of drainage systems and a mid -
slope bench was found to be a better location for the road. Altogether, in 50 miles
of proposed roads, there are only 23 proposed road crossings over jurisdictional
streams. All such crossings, however, will be bridged with no impacts to Waters
of the US (Figure 12). These crossings are considered necessary for safety and
for overall project quality.
Another example of avoidance is the design of the project's on-site water and
sewer system. First, to the extent possible the design places all underground
water and sewer lines in the proposed road sections. This option is expensive
because it requires the use of numerous pump stations throughout the site for
the sewer rather than relying primarily on gravity lines. The design was selected,
however, to reduce stream crossings and wetland and buffer impacts that would
occur if gravity sewer lines were used exclusively.
Second, sewage effluent will be treated to reuse standards and used to
supplement irrigation needs for the golf courses through spray and drip
application. There are additional non -golf course areas designated for drip
irrigation if during certain peak flow times of year moisture conditions on the golf
course preclude irrigation and for times when storage capacity becomes limited.
There will be large storage tanks constructed to store treated effluent for up to 3
months to allow for effluent to be applied when soil moisture conditions are
favorable. The result is that there will be no direct discharges of treated effluent
to any streams on or off the site.
Laurelmor 404/401 Page 65 of 94 2/1/2006

Avoidance, Minimization, and Mitigation
3. Avoidance and minimization of future impacts — Potential future
impacts caused by subsequent development have been anticipated and
mitigated. The layout of individual residential lots has been designed so that no
streams or buffers will be included in those lots. Instead, all streams, wetlands
and buffers will remain in the Applicant's control and will be held in common area
or conservation easements and permanently protected. In fact, early in the
project development phase of the Laurelmor project E'nV Inc. was charged with
the creation of a comprehensive conservation plan for the entire project area.
Initial contacts were made with local land trusts and an agreement was reached
with the Blue Ridge Rural Land Trust to hold conservation easements over much
of the open land within the development. The development of this plan has
involved consideration of numerous factors including the assessments of streams
and wetlands on the site, a natural resource habitat assessment, a cultural
resource site assessment, and consideration of the site as a significant corridor
for migratory birds and butterflies. The plan has also considered the proposed
development and identified areas that are not available for conservation. The
resulting plan currently includes suitable areas in excess of 1000 acres
encompassing over 60 miles of riparian corridor. This plan will continue to evolve
as residential lots are final platted and precise easement boundaries can be
determined. The Applicant expects that ultimately over 2000 acres of the project
will be placed into permanent conservation easements. There will be an
extensive pedestrian trail network through this area and a more limited network
of equestrian trails. While this trail network has not yet been designed, all
necessary stream crossings will be bridged such that there will be no impacts to
jurisdictional Waters of the US.
4. Avoidance of impact through Property acquisitions and cooperation
The Applicant has endeavored to establish a good working relationship with all of
its neighbors during the early stages and throughout this project. These efforts
have resulted in several examples of how cooperation and compromise can
result in environmental protection. For example, adjacent property owners have
agreed to allow access through their property to remote areas of the site for
various activities including well drilling. These mutually beneficial arrangements
have eliminated the need for extensive trailing through streams, wetlands and
steep wooded areas to gain temporary access to certain areas. In another case,
an adjacent landowner was harvesting timber and asked to use existing logging
roads on the Applicant's property to remove the timber. After evaluation of this
request the Applicant determined that the timber would have to be dragged
through Dugger Creek in order to reach the loading area. To prevent this, the
Applicant agreed to pay the adjacent landowner the value of the timber in lieu of
allowing the logging machinery to disturb the creek.
The Applicant has also elected to purchase additional adjacent property to avoid
wetland and stream impacts. An example of this is at the Triplett Road entrance
to the site where DOT requirements for a flared connection would have required
impacts to wetlands adjacent to the existing logging road. Furthermore, design
Laurelmor 404/401 Page 66 of 94 2/1/2006

Avoidance, Minimization, and Mitigation
standards for vertical slope and curve radius would have resulted in impacts to a
springhead a short distance from Triplett Road in this same area. The Applicant
bought the adjacent property, to avoid filling these areas. The Applicant now
uses the purchased home as the site construction office.
Also with respect to cooperation, the Applicant recognizes that Laurel Creek is a
prime and highly valued fishing area. During the review process for the Heavenly
Mountain Resort 404/401 permit a request was made to allow public access,
through the development, for fishing in Laurel Creek. Ginn LA has committed to
allowing public access to Laurel Creek through the development and has
adopted a policy for this purpose. A copy of this policy is included in Appendix E.
5. Minimization of unavoidable impacts through promect design and
implementation of the work — As noted above, project impacts have been
avoided to the point where the only affected waters are limited to those
associated with the golf courses. Numerous alternative layouts and designs
have been considered to avoid and minimize impacts to the maximum extent
practicable.
Lakes- Early in the project planning phase for Laurelmor the entire property was
evaluated for areas that would be suitable for the creation of lakes. The initial
goal was to find areas where off-line ponds could be constructed that would meet
design objectives. Due to the steep topography and the abundance of water, no
suitable off-line sites could be found that were capable of providing a lake with
greater than 5 acres surface area and that would provide sufficient irrigation
water for the golf courses.
Thirteen (13) sites were mapped and evaluated across the site, some of these
were ruled out quickly due to the lack of local terrain compatible with golf course
development. Table 6 provides an analysis of these alternative lake location by
showing stream and wetland impact associated with each and a ratio of potential
lake surface area to impact quantity. The lake alternative selected is the least
impacting practicable alternative of those identified. The ratio of linear feet of
stream impact to potential surface area is 187-1, the lowest impact ratio of all
those considered. The next least impacting alternative is #8 with a ratio of 217-1
for stream impact. Wetland impact associated with the selected alternative is also
minimal when compared to many of the other sites evaluated. A map of the
alternate lake locations is provided in Appendix F.
Golf Course Alternatives- Over the past year the Applicant has engaged three
separate golf course design groups to evaluate the Laurelmor property and
propose workable layouts for both 18 -hole independent courses and 36 -hole
combined courses. Given the size of the property and the scale of the proposed
development a total of 36 golf holes has been a guiding design principle from the
outset. Numerous attempts were made early in the process to make minor
modifications to the golf course previously permitted by Kaplan Holdings LLC, but
these efforts did not produce acceptable results.
Laurelmor 404/401 Page 67 of 94 2/1/2006

Avoidance, Minimization, and Mitigation
Table 6. Alternative Lake Analvsis Laurelmor Proiect Site
Alt.
Proposal
Stream
Surface Impacts
Area (ac) (If)
Ratio
Wetland
Impacts
(sf)
Ratio
Proposed
17.4 3,253
187:1
4,000
230:1
1
7.65 2,651
346:1
5,067
662:1
2
8.57 2,471
288:1
4,387
512:1
3
6.11 1,447
237:1
7,940
1,300:1
4
16.46 3,964
238:1
0
0
5
3.21 834
260:1
0
0
6
29.62 7,141
241:1
16,963
573:1
7
3.07 788
257:1
3,371
1,098:1
8
7.33 1,592
217:1
3,194
436:1
9
8.44 3,090
366:1
0
0
10
4.73 1,693
358:1
0
0
11
3.11 789
254:1
0
0
12
9.09 2,074
228:1
11,273
1,240:1
Of the tens of layouts considered seven are shown here that include the most
feasible of those considered. All the alternatives considered here are 36 -hole
combined courses. This configuration allows for shared clubhouse, driving range
and parking facilities and therefore reduces land disturbance and impervious land
cover. Conversely, this configuration creates a greater design challenge because
four 9 -hole loops need to begin and end in the vicinity of the clubhouse. The
selected alternative represents the least impacting layout by far of those
considered feasible. Impacts considered in this analysis are only those
associated with the grading of the golf course, impacts associated with lake
creation are considered elsewhere in this section. Stream impacts for the
selected alternative (36 -holes) total 1505 linear feet. The next least impacting 36 -
hole alternative would involve 2195 linear feet of total stream impact. The
impacts to perennial streams, intermittent streams, and wetlands for each
alternative are summarized in Table 7, maps showing the location of each of the
alternatives and the impact areas on each are contained in Appendix G.
Table 7. Alternative Golf Course Lavout Analvsis
LayoutlD
Driving
Range
Perennia I
(If)
Intermittent
Impacts (If)
Total
Stream
Impacts (If)
Wetland
Impacts (sf)
Proposall
ye
233
307
540
1,484
Proposa12
0
965
965
0
Alt.1, 1-18
yes
1,403
252
1,655
7,546
Alt.2, 1-18
2,036
1,948
3,984
1,484
Alt.3, 19-36
1,902
1,077
2,979
0
Alt.4, 1-18
yes
384
1,1741
1,558
1,143
Alt.5, 19-36
1,183
1,2251
21408
0
Laurelmor 404/401 Page 68 of 94 2/1/2006

Avoidance, Minimization, and Mitigation
The two proposed golf courses involve the largest concentration of land
disturbing activity and consequently posed the greatest challenge to avoid and
minimize impacts to Waters of the US. When the Applicant initially purchased the
property (5600 acres) there was a permitted project associated with a 1200 -acre
portion of the tract. This project (Heavenly Mountain Resort (HMR) Golf Course)
was permitted on November 24, 2003 under the name of Kaplan Holdings LLC
with Action ID- 200330353. The Applicant decided not to construct the previously
permitted course primarily because of the almost 1100 linear feet of required
stream relocations and a large amount of additional steep slope grading in close
proximity to streams that would have left the golf course with a forced
appearance and not allowed for the natural beauty of the site to be fully featured.
An additional drawback of the initial golf course design was that it lacked
significant water features. As described below, these water features are critical
to irrigation, fire safety and playability of the courses.
The proposed golf courses are designed primarily as ridge top courses in
contrast to the HIVIR course, which was primarily a valley course. The change to
a ridge top course was made possible by having more land to work with, 6050
acres verses 1200 acres and a difference in development philosophy. Typical
golf course developments place a strong emphasis on maximizing the number of
"prime" lots adjacent to the golf course with views both to and from the golf
course. The current golf course concept de-emphasizes the premium on adjacent
lots and allows the ridge top areas to be used for golf course instead of lots.
There are some portions of the two golf courses that are adjacent to lots but an
examination of the course layout reveals that this was not a governing principle in
designing the layout.
The challenges in laying out a high quality golf course are immense. Each course
needs to meet specific length requirements, needs a balance and comfortable
mix of par 3, par 4, and par 5 holes, it needs to blend with the topography and
natural environment, and incorporate some of these natural features as hazards.
There needs to be a flow that begins and ends in the same general area, and
each golf hole must be both playable and aesthetically pleasing. When these
design challenges are combined with the even more critical goal of minimizing
impacts to jurisdictional Waters of the US, the task becomes especially difficult.
In the case of the Laurelmor project, golf course designers explored numerous
layouts, including multiple attempts to modify the previously permitted Heavenly
Mountain Resort course layout, before settling on the current location. The
primary focus in this effort was reduction of impact to jurisdictional streams.
The proposed course #1 layout basically plays along ridges and across stream
valleys. In most cases playing across stream valleys allows for the stream
corridor and riparian buffer to be left intact with only a selective cutting impact to
the buffer associated with removal of the tall trees that would create a barrier to
play. The proposed course #2 layout is also primarily along ridges and across
valleys with a few holes planned along the lower shoulders and high terraces
Laurelmor 404/401 Page 69 of 94 2/1/2006

Avoidance, Minimization, and Mitigation
near Dugger Creek. There are no proposed impacts to the main stem of Dugger
Creek.
The advantages of the ridge top layout approach for both proposed golf courses
is also evident when considering that total impacts related to grading, on both
courses, excluding the driving range, will be only 1115 linear feet of small
intermittent streams and no wetland impact. While no impact to jurisdictional
waters is considered insignificant, this number represents a major effort at
avoidance and minimization when considering the amount of grading that will
occur in the process of constructing two complete golf courses.
While the ridge top golf course layout allows for a more desirable course it lacks
any water features and will require significant quantities of irrigation water. The
proposed lakes will serve as water features, considered essential, for several golf
holes on both proposed courses, and will provide a valuable source of irrigation
water. It should also be noted that these proposed lakes will be vital components
of the on-site and regional fire fighting infrastructure. The Laurelmor project is
located in a rugged, high wildfire danger area according to the NC Forest
Service. In a meeting with Hunter Birckhead, District Forester for the region, Mr.
Birckhead emphasized the benefits of ponds and lakes both for the proposed
project and for adjacent properties. Mr. Birckhead has written a letter
summarizing the meeting, in which he supported the proposed lake and
emphasized that "the construction of lakes will assist us greatly in being able to
utilize our helicopters in getting water quickly to needed areas" (see attached
NCFS letter in Appendix D). He added, "The larger the lake and the amount of
water it contains, the better off the community will be. It would be great if you
have the opportunity to construct other lakes on the property as well."
Golf course impacts are further minimized in the layout of the golf cart paths.
The proposed golf cart network will consist of approximately 13.5 miles of paved
trails that will employ only no -impact crossings. As noted above, the only
impacts to waters of the United States are associated with the construction and
grading of the golf courses themselves.
We also direct you to the application narrative for a discussion of storm water
management and soil and erosion control features implemented for this project.
6. Mitigation of unavoidable impacts — The above discussion
demonstrates the comprehensive planning effort to first avoid jurisdictional areas
and then to minimize impacts to the extent practically feasible. The remaining
impacts that are considered unavoidable are noted above and in Table 2. The
Applicant looks forward to working closely with the USACE, NCDWQ, and other
agencies and interested parties in the development of a compensatory mitigation
plan that meets all applicable requirements and will best serve the ecosystem
and natural resources in the immediate project area and the Upper Yadkin River
Basin.
Laurelmor 404/401 Page 70 of 94 2/1/2006

Avoidance, Minimization, and Mitigation
It should be noted that as part of the previously issued permit for this property,
which has not been used, a single payment of $83,000 was made to cover 415
linear feet of stream impact. The Applicant respectfully requests that this
previous payment would be credited towards the overall mitigation requirement
for the project.
Laurelmor 404/401 Page 71 of 94 2/1/2006

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Laurelmor 404/401 Page 72 of 94 2/l/2006
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Laurelmor 404/401 Page 72 of 94 2/l/2006

Figure 15
Laurelmor 404/401 Page 73 of 94 2/l/2006
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Laurelmor 404/401 Page 73 of 94 2/l/2006

Figure 16
Laurelmor 404/401 Page 74 of 94 2/l/2006

Figure 17
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Laurelmor 404/401 Page 75 of 94 2/l/2006

Appendix A. Adjacent Land Owners to Laurelmor Property
AppendixA
BLOCK 24
PARCELID
ADDRESS
OWNER NAME
CITY, STATE
ZIP
STREET
2857-35-7070
SETSER, YUN CHING
1061 REMINGTON DR
CONOVER, NC
28613
2857-35-5318
SETSER, YUN CHING
1061 REMINGTON DR
CONOVER, NC
28613
2857-35-0477
JAMES, DAVID L, RENEE T
14 LINESTOWE DRIVE
BELMONT, NC
28012
2857-26-7088
MCRARY, POLLY S
2787 CAMPGROUND RD
GRANITE FALLS, NC
28630
2857-26-3388
BARTTRUM, CLARENCE M,
8232 PANAHAN DR
BROOKSVILLE, FL
34613
CAROLA
2857-26-0716
HINSON, ELLEN SLOAN
222TENNESSEE
MOORESVILLE, NC
28115
CIRCLE
2857-17-5079
HINSON, ELLEN SLOAN
222TENNESSEE
MOORESVILLE, NC
28115
CIRCLE
2857-17-3224
HAWKINS, ETHELBERT W
1400 DOVER FORT
DOVER,NC
28526
BARNWELL RD
2857-06-8939
KLUGLEIN, JOANNE C
158 SW S DARRVI LLE
PORT ST LUCIE, FL
34953
CIRCLE
2857-07-7686
PAGE, WILLIAM L WI REN,
6475 BOULDER DR
YORK, SC
29745
MINDY L
2857-08-2041
BROWN, JOHN R, OTILIA L
2703 NORTH WOODS
JACKSONVILLE, NC
28540
DR
2847-98-5383
ALLEN, GRADY L HUNTER,
PO BOX 421646
HOUSTON, TX
77242
LINDA P
2847-98-1113
STALLARD, CECIL & SUSAN
519 MARGARET DR
STATESVILLE, NC
28677
2847-88-9223
BARRETT, JOHN E 3RD,
351 OLD FARM RD
LURAY,VA
22835
WENDY L
2847-88-8479
FRANCES JAFFEE 1996
6516 MORROWICK
CHARLOTTE,NC
28226
TRUST
CIRCLE
2847-88-7735
YARCHIN, JEFFREY,
6516 MORROWICK
CHARLOTTE,NC
28226
SANDRA ROBERTS
CIRCLE DR
Laurelmor 404/401 Page 76 of 94 2/11/2006

AppendixA
Laurelmor 404/401 Page 77 of 94 2/11/2006
ADDRESS
PARCEL ID
OWNER NAME
CITY, STATE
ZIP
STREET
2847-88-6834
MULL, CURTIS M JR,
2115 CLINCHFIELD DR
FAYETTEVILLE, NC
28304
SANDRA
2847-88-5932
BALDREES PROPERTIES
PO BOX 975
NEW BERN, NC
28563
LLC
2847-89-5038
BALDREES PROPERTIES
PO BOX 975
NEW BERN, NC
28563
LLC
2847-89-5244
ALVAREZ, MARCOS,
5702 CHALYCE LANE
CHARLOTTE,NC
28270
LAUREN
HEY, DAVID A, SUSAN &
2847-89-5445
GEORGE ROBERT DAVIS,
702 WILLOUGHBY RD
MONROE, NC
28110
VALERIE K
2847-89-4666
CAMBRON,ROBERTL
PO BOX 1727
BOONE, NC
28607
PHILLIPS, SANDRA P
2847-89-4950
CAMBRON,ROBERTL
PO BOX 1727
BOONE, NC
28607
PHILLIPS, SANDRA P
2848-80-5171
CAMBRON,ROBERTL
PO BOX 1727
BOONE, NC
28607
PHILLIPS, SANDRA P
2848-80-8109
CONNELL, PETER JOHN
9150 PARK BLVD #2
LARGO,FL
33777
2848-80-6418
KELLISON, ARTHUR J,
410 REGALWOOD DR
JACKSONVILLE, NC
28546
CAROLJ
2848-80-3452
CRISAFULLI, DANIEL,
1971 W SANDPIPER RD
VERO BEACH, FL
32963
SAMANTHA
2848-70-3606
CLARK,DONALD
3932 LAKESHORE RD S
DENVER,NC
28037
2848-50-9888
COFFEY, S OWEN, BETTY
507 EDMISTEN RD
BLOWING ROCK, NC
28605
2848-31-7814
WATSON, EDWARD H
PO BOX 363
PATTERSON, NC
28661
2848-33-2493
TONEY, ROY LEE, MARY
1111 SUNSET RD
CHERRYVILLE, NC
28021
JANE
2848-31-7814
WATSON, EDWARD H
PO BOX 363
PATTERSON, NC
28661
2848-00-7684
BRIDGES, JOSEPH
PO BOX 3352
BOONE, NC
28607
2848-02-9380
STOWE, HENRY G, BESSIE
BOX 295
BELMONT, NC
28012
P
Laurelmor 404/401 Page 77 of 94 2/11/2006

AppendixA
Laurelmor 404/401 Page 78 of 94 2/11/2006
ADDRESS
PARCEL ID
OWNER NAME
CITY, STATE
ZIP
STREET
2838-93-7257
HEDRICK, CHRISTOPHER
1846 HICKORY
LINCOLNTON, NC
28092
SCOTT
SPRINGS LANE
2838-84-0199
CARROLL, STERLING
PO BOX 1549
BOONE, NC
28607
2838-64-3700
CHAPMAN, DONNA CHERYL
2521 HIGHLAND FARM
HILLSBOROUGH, NC
27278
RD
2838-44-9527
CHAPMAN, DONNIE
2521 HIGHLAND FARM
HILLSBOROUGH, NC
27278
HAROLD
RD
2838-35-4129
COFFEY, JIMMY D
2247 SAMPSON RD
BOONE, NC
28607
2838-36-5855
PAAL, JAMES P AND
688 WINDWOOD LANE
BOONE, NC
28607
PATRICIA
2838-37-6041
HEIDINGSFELDER, HILDA
4718 ST CHARLES AVE
NEW ORLEANS, LA
70115
GAY GUZZETTA, N INA A
2838-38-7600
MOUNTAIN VIEW
22355 CARBON MESA
MALIBU, CA
90265
HOLDINGS LLC
RD
2838-78-2927
MAHARISHI SPIRITUAL
1896 HEAVENLY
BOONE, NC
28607
CENTER OF AMERICA
MOUNTAIN DR
2849-00-3563
MAHARISHI SPIRITUAL
1896 HEAVENLY
BOONE, NC
28607
CENTER OF AMERICA
MOUNTAIN DR
2849-11-5098
HEAVENLY MOUNTAIN
1896 HEAVENLY
BOONE, NC
28607
RESORT INC
MOUNTAIN DR
2849-43-9746
HEAVENLY MOUNTAIN
1896 HEAVENLY
BOONE, NC
28607
RESORT INC
MOUNTAIN DR
2849-60-1622
MAHARISHI SPIRITUAL
1896 HEAVENLY
BOONE, NC
28607
CENTER OF AMERICA
MOUNTAIN DR
2849-81-9721
MAHARISHI SPIRITUAL
1896 HEAVENLY
BOONE, NC
28607
CENTER OF AMERICA
MOUNTAIN DR
2849-84-8236
STEVENS, JOHN AUSTIN,
718 SUNSET MOUNTAIN
BOONE, NC
28607
RACHEL, MIRANDA ALLENE
RD
2859-13-0242
BRIGHTWOOD 1 11 & III POA
PO BOX 3469
BOONE, NC
28607
2859-13-4804
GAYDEN, MCGAVOCK,
2219 FREEDOM TRAIL
DEEP GAP, NC
28618
MAC, DIANE B
2858-79-4186
POWDER HORN MTN. POA
1568 POWDER HORN
DEEP GAP, NC
28618
RD
Laurelmor 404/401 Page 78 of 94 2/11/2006

AppendixA
Laurelmor 404/401 Page 79 of 94 2/11/2006
ADDRESS
PARCEL ID
OWNER NAME
CITY, STATE
ZIP
STREET
2859-21-6941
POWDER HORN MTN. POA
1568 POWDER HORN
DEEP GAP, NC
28618
RD
2868-06-6057
HERR, KAREN LRENTZER,
1189 HILLSBORO MILE
POMPANO BEACH, FL
33062
RANDI
#6
2868-05-6756
BRADLEY, SYLVIA K
98 COLUMNS CIRCLE
SHELBY,NC
28150
2868-05-5464
FOSTER, DEBORAH S
2107 OLD MOUNTAIN
THOMASVILLE, NC
27360
RD
2868-05-6128
RENNY,SUSAN
9264 ELK CREEK RD
DEEP GAP, NC
28618
2868-04-5602
POTTS, BEVERLY ANN
9266 ELK CREEK RD
DEEP GAP, NC
28618
2868-04-7112
GRIFFIN, JAMES W, JANET
215 SUITE B
RALEIGH, NC
27603
M
GLENWOOD AVE
2868-03-9647
SCIABARASI, DAVID
5341 ROCK SERVICE
RALEIGH, NC
27603
STATION RD
2868-13-2000
ARNETTE, JAMES MICHAEL,
315 TOLARSVILLE RD
LUMBERTON,NC
28358
CRAE
2868-12-1396
LOHMAN, TERRENCE J,
106 BARN BRIDGE
APEX,NC
27502
LINDA B
COURT
2868-11-1717
PEYSER, JOHN ROBERT
1212 OXFORD RD
CLEVELAND, OH
44121
HORACK, THOMAS B JR,
12502 HAWKS RIDGE
2868-11-9605
AMY H, WILLIAM S,
RD
HUNTERSVILLE, NC
28078
PATRICIA H
2868-10-6897
WRONKO, RAYMOND J,
6337 CHAUCER DR
OCEAN SPRINGS, MS
39564
MARY M
2868-11-4084
HARRISON, SHUFORD
PO BOX 887
MILLERS CREEK, NC
28651
EDWARD
2868-20-0401
COUGHENOUR, KENNETH
2175 POTNECK RD
SALISBURY, NC
28144
2857-34-8749
SETSER, YUN CHING
1061 REMINGTON DR
CONOVER, NC
28613
BERTRAND, MARGARET E &
178 MILLS FOREST
MOORSVILLE, NC
28117
2857-34-6210
STEPHEN M
LANE
2857-33-5185
BERTRAND, MARGARET E &
178 MILLS FOREST
MOORSVILLE, NC
28117
STEPHEN M
LANE
WHIRLOW, FRED W
2315 STOKES FERRY
SALISBURY, NC
28146
2857-43-3366
RD
2857-43-7174
BELLAMY, HOYT C JR &
1 000-A FIFTH AVE, S
MYRTLE BEACH, SC
29577
PATTY H
I
I
2857-52-2732
BELLAMY, HOYT C JR &
1 000-A FIFTH AVE, S
MYRTLE BEACH, SC
I
29577
I
PATTY H
Laurelmor 404/401 Page 79 of 94 2/11/2006

AppendixA
Laurelmor 404/401 Page 80 of 94 2/11/2006
ADDRESS
PARCEL ID
OWNER NAME
CITY, STATE
ZIP
STREET
2857-52-7797
HOLLOMAN, BILLY CARLIE
195 HOLLOMAN LANE
DUDLEY, NC
28333
& JONES, JOHNNY STEVEN
2857-62-5707
GIBSON, PATRICIA
PO BOX 97
OCRACOKE, NC
27960
2857-72-2543
GIBSON, PATRICIA
PO BOX 97
OCRACOKE, NC
27960
2857-72-9106
POTTER, DELLA W
247 NOAH RD
BENSON,NC
27504
BORCICH, MEREDITH B &
%VIVIAN FISHER 4534
BOSTON,JONATHAN
ICARD RIDGE RD
HICKORY, NC
28601
2857-82-8425
ROBERT ET AL.
CORRADO, FRANK L &
207 ASHLEY RD
PLATTSBURGH, NY
12901
2857-72-7486
ROSEANNE B
2857-82-8154
WOODS, FRED G & SANDRA
7974 ELK CREEK-
FERGUSON,NC
28624
B
DARBY RD
2857-82-9830
WOODS, FRED G & SANDRA
7974 ELK CREEK-
FERGUSON,NC
28624
B
DARBY RD
2857-92-6822
WHITSON, PERRY ROBERT
7872 ELK CREEK
FERGUSON,NC
28624
&JUDY
DARBY RD
MINTON, DAVID CARROL &
467 TRIPLETT RD
FERGUSON,NC
2867-03-9741
PHYLLIS
28624
2867-14-1122
MINTON, KENNETH LEE &
493 TRIPLETT RD
FERGUSON,NC
28624
DORIS ANN
2867-14-1722
DULA, JACK W & Reva L.
806 MANCHESTER
LENOIR, NC
28645
STREET SW
2867-25-0297
ROBBINS, JASON TODD
5609 ELK CREEK
LENOIR, NC
DARBY RD
28624
2867-35-3348
EDMISTON, DIXIE H
6890 ELK CREEK
FERGUSON,NC
28624
DARBY RD
2868-74-3568
JOHNSTON, KEITH W
P 0 BOX 628
MORAVIAN FALLS, NC
28654
2868-74-3568
JOHNSTON, KEITH W
P 0 BOX 628
MORAVIAN FALLS, NC
28654
2868-74-3568
JOHNSTON, KEITH W
P 0 BOX 628
MORAVIAN FALLS, NC
28654
2868-20-1248
COUGHENOUR, KENNETH
2175 POTNECK RD
SALISBURY, NC
28144
Laurelmor 404/401 Page 80 of 94 2/11/2006

Appendix B
BLOCK 25
Appendix B.
LISTING OF ACQUIRED PERMITS
GINN-LA LAUREL CREEK LTD., LLLP
WATAUGA and WILKES COUNTY, NORTH CAROLINA
Laurelmor 404/401 Page 81 of 94 2/l/2006
DATE
DATE
PERMITTING
TYPE OF PERMIT
SUBMITTED
APPROVED
AUTHORITY
& PERMIT NO.
HEAVENLY
12-06-01
01-02-02
NCDENR
EROSION
MOUNTAIN GOLF
CONTROL
COURSE ACCESS
(WILKES CO.)
(WILKES CO.)
PROJECTID#
ROAD — WILKES CO.
(N('DENR
WILKE 2002-017
SECTION B)
HEAVENLY
02-19-02
02-25-02
NCDENR
EROSION
MOUNTAIN ACCESS
CONTROL
ROAD - WATAUGA
PROJECTID#
Co.
(N('DENR
WATAU 2002-005
SECTION 1)
SECTION 1
12-22-04
1-24-05
NCDENR
EROSION
MAIN ACCESS ROAD
CONTROL
PROJECTID#
(N('DENR
NOI dismissed
WATAU 2005-002
SECTION 2)
03-29-05
Rev. Approved
04-08-05
SECTION 2
02-25-05
03-21-05
NCDENR
EROSION
ROAD A, SPUR A,
CONTROL
ROAD B, LOOP S,
PROJECTID#
LOOP SPUR -5
WATAU 2005-003
(N('DENR
SECTION 3)
SECTION 3
03-09-05
03-23-05
NCDENR
EROSION
ROAD C, LOOP N,
CONTROL
LOOP SPUR -1
PROJECTID#
(N('DENR
WATAU 2005-004
SECTION 4)
Laurelmor 404/401 Page 81 of 94 2/l/2006

Appendix B
Laurelmor 404/401 Page 82 of 94 2/1/2006
SECTION 4
04-08-05
05-03-05
NCDENR
EROSION
MAIN ACCESS RD.
CONTROL
ENTRANCE AT
(WILKES CO.)
(WILKES CO.)
PROJECTID#
SR 1162 — WILKES
WILKE 2005-026
Co.
(NCDENR
SECTION A)
SECTION 5
05-13-05
6-07-05
NCDENR
EROSION
ROAD A EXT., ROAD
CONTROL
B EXT., ROAD C
PROJECTID#
REVISED, ROAD D
WATAU 2005-005
(formerlv LOOP S�
SPUR D I (formerlv
SPUR -5)
(NCDENR
SECTION
SECTION 6
6-08-05
6-14-05
NCDENR
EROSION
NORTH LOOP
CONTROL
EXTENTION, SOUTH
PROJECTID#
LOOP
WATAU-2005-006
(NCDENR
SECTION 6)
SECTION 7
7-13-05
8-3-05
NCDENR
EROSION
PHASE I OF MAIN
CONTROL
ACCESS EXTENTION
PROJECTID#
(NCDENR
WATAU 2006-001
SECTION 7)
SECTION 8
7-22-05
8-18-05
NCDENR
EROSION
PHASE 2 OF MAIN
(plans)
CONTROL
ACCESS EXTENTION
PROJECTID#
(NCDENR
WATAU-2006-002
SECTION 8)
Laurelmor 404/401 Page 82 of 94 2/1/2006

Appendix B
EXPRESS
8-22-05
8-29-05
NCDENR
EROSION
PERMITTING
CONTROL
WELL
PROJECTID#
DRILLING &
WATAU-2006-003
STOCKPILE
AREA
EXPRESS
9-22-05
9-30-05
NCDENR
EROSION
PERMITTING
CONTROL
2 ND SUBMISSION
PROJECTID#
TEST BORINGS
WATAU 2006-006
EXPRESS
10-21-05
10-25-05
NCDENR
EROSION
PERMITTING
CONTROL
3 RD SUBMISSION
PROJECTID#
TEST BORINGS
WATAU 2006-007
EXPRESS
10-26-05
10-27-05
NCDENR
EROSION
PERMITTING
CONTROL
GOLF HOLES #1
PROJECTID#
AND#2
WATAU 2006-008
EXPRESS
12-06-05
12- -05
NCDENR
EROSION
PERMITTING
CONTROL
4 TH SUBMISSION
PROJECTID#
ACCESS TRAILS
DUGGER
CREEK AREA
STREET/
11-07-03
11-12-03
NC DOT
DRIVEWAY
DRIVEWAY
05-02-05
PERMIT
PERMIT
SR 1166 WILKES
ACCESS
CO.
(WILKES CO.)
Laurelmor 404/401 Page 83 of 94 2/l/2006

Appendix B
Last ipdate: 01-18-06 Bv: CDB
McGill Associates
Laurelmor 404/401 Page 84 of 94 2/1/2006
DAVID KAPLAN
12-28-04
02-10-05
DWQ
STORM WATER
GOLF COURSE
02-10-05
PERMIT NO.
DEVELOPMENT
SW4041201
WASTE WATER
09-22-05
11-30-05
NCDENR
WWTP &
DISPOSAL
DWQ
RECLAIMED
SYSTEM
WATER
UTILIZATION
SYSTEM
PERMIT NO.
WQ0029346
Last ipdate: 01-18-06 Bv: CDB
McGill Associates
Laurelmor 404/401 Page 84 of 94 2/1/2006

LAURELMOR PROJECT PHOTO SHEETS Appendix C
Typical Stream & Wetlands #1
Looking West Over Dugger Valley
across Laurelmor project area
Riparian Wetland along Dugger Creek
Lower Dugger Creek
Pool along Lower Dugger Creek
Riffle -Pool Sequence along Dugger Creek
Slide along Dugger Canyon
Laurelmor 404/401 Page 85 of 94 2/1/2006

LAURELMOR PROJECT PHOTO SHEETS Appendix C
Typical Stream & Wetlands #2
Flat Branch a Tributary of Laurel Creek
Wetland on Unnamed Tributary of Dugger
Creek
Wetland on Unnamed Tributary of Dugger
Creek
Rhododendron thicket along Swift Ford
Upper Reaches of Horton Branch
Wet meadow site in the Dugger watershed
Laurelmor 404/401 Page 86 of 94 2/1/2006

LAURELMOR PROJECT PHOTO SHEETS Appendix C
Examples of Proposed Utility and Golf Course Crossings
Example of restored temporary utility
line crossing #1.
Above are three examples of golf cart crossings from The
Rock Barn golf course near Hickory N.C. They were built
under the supervision of the same golf course contractor hired
by Ginn Golf. These types of crossings can span over 100 feet
and are typical of the non impact stream crossings intended
for use on the Laurelmor Project.
Example of restored temporary utility
line crossing #2.
Laurelmor 404/401 Page 87 of 94 2/1/2006

N
'Norill CaT06133
Dcpattmnt of Enviroiuncnt and
Nalftiral Resattm=
Michad F. Easley, Governor
WE,= G. Ross Jr., Secretary
Vop 17171n; - k; =-#-rim
Ginn Clubs and Re�oil�
389 Uttle laurel Road Ext.
Boone, NC 286o7
Dear Mr. Miller.
Appendix D
North Carolina
Division of Forest Resources
Stanford M. Adams, Direclor
adjacent to yours.
ur
is
'?IaAW
VA". 1W.WTIRKM W
I BvIi
will be. It would be great if you have the OPPOrtInitY to cOnSMIct other lakes on the
property as well.
If You have any questions, or if we can be of othe ' r assistance, please don't hesitate to
call District Ranger Jeff Bums or me at 828-757-56il,. Thank you again for taking the
fire danger seriously and keeping us informed.
Since7ly, 0 �
//, , � Z?'J V-). , � 4 � I
Hunter Birckhead, RF#679
District Forester, NCFS
Plmnc: 919 - 733-2162 � FAX: 919 - 733-0130 � hiternet;
ANF;QUAi,OPPOf(TtJWITY\AFPIRMATIVr-,ACTFO,Nr�Mrl-OyL71t-
CONSUMM PAPER 50% RECYCLED 1 [00/0 POST
Laurelmor 404/401 Page 88 of 94 2/1/2006

Appendix E
PUBLIC ACCESS FISHING POLICY
Public fishing will be allowed along designated sections of Laurel Creek provided all of the
following rules and restrictions are strictly followed. Failure to strictly follow all of the
following rules and restrictions will result in a revocation of fishing access privileges for all
individuals involved. The determination of when an individual has not strictly followed the rules
and restrictions of this policy will be made by an appointed committee to be designated by the
Master POA Executive Committee.
RULES AND RESTRICTIONS:
Public access fishing is allowed by reservation only. Reservations can be made through
security. Reservations will be granted on a first-come/first-serve basis with no more than
4 vehicles allowed inside the resort at any time and no more than 4 passengers per
vehicle.
2. Public access fishing is allowed only between sunrise and sunset on designated days.
Public access fishing is allowed only on Tuesdays through Saturdays, between April 15
and October 15.
4. Public access fishing is allowed only through the main entrance gate located off of
Sampson Road. All those wishing to fish must both check in and check out from this
gate.
5. All those wishing to enter the property for public access fishing must display a valid NC
fishing license upon entrance.
6. All those wishing to enter the property for public access fishing must register at the
entrance gate by completing a form with the following information:
a. Name
b. Address
c. Vehicle make, model, license 4 and color
d. Time of arrival
e. Time of intended departure
f. Name and address of each additional occupant of vehicle
7. All those wishing to enter the property for public access fishing must obey all traffic
signs, speed limits and other posted rules of the development.
8. All those wishing to enter the property for public access fishing must only park in the
designated Public Access Fishing parking lot.
9. All those wishing to enter the property for public access fishing must stay on designated
Public Access Fishing paths.
10. No alcoholic beverages permitted by the public while fishing on the property.
Laurelmor 404/401 Page 89 of 94 2/1/2006

Appendix F
misn
Hill �TtRRR!�, 'I I AH U A
5w 0
EL
Laurelmor 404/401 Page 90 of 94 2/l/2006

Appendix G
Laurelmor 404/401 Page 91 of 94 2/l/2006

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Laurelmor 404/401 Page 92 of 94 2/l/2006

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Laurelmor 404/401 Page 93 of 94
Appendix G
-,am S�Xzum
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2/l/2006

Appendix G
Laurelmor 404/401 Page 94 of 94 2/l/2006
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Laurelmor 404/401 Page 94 of 94 2/l/2006