20080880 Ver 1_Public Comments_20080731 (7)

Cliffs application to NCDWQ
Subject: Cliffs application to NCDWQ
From: Rebecca Williams <serpentchi ld@earthlink. net>
Date: Thu, 31 Jul 2008 18:11:01 -0400 (EDT)
To: [e-mail]
Dear Ms. Karoly,
7/31/08
I am writing in regards to the application from the Cliffs Communities to the US
Army Corps of Engineers (Corps Action ID # 200701619) and the North Carolina
Division of Water Quality to impact approximately 6149 linear feet of stream
channel, 0.219 acres of wetlands and 0.03 acre of open water in order to construct
the golf course and residential development, known as the Cliffs at High Carolina.
To the many community members who live downstream of the proposed Cliffs
development, this application raises several potential concerns and questions.
First, wetlands regulations call for attempts to be made on avoidance, minimization
and mitigation of wetland impacts, in that order. Although we note the presence of
wetland mitigation, has the developer made any attempt to avoid and or minimize
wetland impacts?
Second, according to our calculations regarding the stream crossing footage
impacts, the developer is averaging 100' of impacted area for each road crossing.
That is far larger than standard. Counties and state standards call for 30, wide
crossings, maximum, for this type/size road.
In addition, we are concerned with the number of culverts associated with road
crossings/construction and golf course construction. Why aren't bridges being used
in at least 10 or 12 of these stream crossings? We request that the USACE and the
NCDWQ require bridges in a certain percentage of the stream crossings to minimize
stream impacts. We also request that "bottomless arches" be explored for other
crossings, which would allow for a more natural streambed and have less of an
impact.
We also have some questions regarding the impact of the golf course. We note that
there are several wetland impacts on the proposed golf course, but it is unclear
how that impact will be handled. Is the plan to bury wetlands and lay a pipe in
their place?
Based on input we have received from residents, there is significant public concern
about chemical runoff from the golf course and its impact on water quality. Over
4000 linear feet of stream channel, as well as wetlands and open water, are
included in proposed impacts for golf course construction. What type and volume of
chemicals are the Cliffs Communities proposing to use on the golf course? What
kind of buffers, other than grass, will be used to keep dangerous chemicals such as
nitrogen, out of the streambeds?
As stated in the application, all stream channels on the site ultimately drain into
the Swannanoa River or Cane Creek; both of which flow into the French Broad River.
There are many traditional fishing holes and swimming holes along the Swannanoa
River where long time residents gather in the river for recreation. What sort of
impact will chemical runoff from the golf course have on the life of the river and
the health and recreational opportunities for Swannanoa Valley residents? We are
aware of a number of residents in Swannanoa and Fairview who rely on well water and
are alarmed about potential runoff and chemical contamination from the golf course
threatening the quality of their water supply. Since all streams on the Cliffs site
lead to the French Broad River, this issue is one of concern to all Buncombe County
residents. Further detail is necessary so that citizens and other groups can
properly analyze and comment on the proposal.
Given the scope of this development and the community concerns about water quality
issues, we believe that the US Geological Survey should conduct a water analysis of
the sub-watershed region on this site. The fact that the streams and wetlands at
High Carolina not only feed into the Swannanoa and French Broad Rivers, but also
make up what could be called the "Fairview watershed," make an analysis of this
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Cliffs application to NCDWQ
sort imperative. This analysis should be conducted before there is additional land
or steam disturbance. In a recent report on steep slope development issued by the
Land of the Sky Regional Council's Mountain Ridge and Steep Slope Advisory
Committee, the panel recommended the following: greater buffers around streams to
preserve water quality, periodic sampling of wells, and evaluation of groundwater
before development begins. We would like the USACE and the NCDWQ to follow all of
these recommendations to insure that the water supply in our region is protected.
The US Fish and Wildlife service's discovery of wild brook trout in stream beds on
the Cliffs site argues for a delay of approval of the application until the Fish
and Wildlife agency can undertake a more thorough evaluation of the diversity of
the wildlife on the 2,780 acre tract of land. This study should be done as soon as
possible, before further development takes place.
Finally, we are concerned by the offsite mitigation that will take place in
Henderson County. We believe that mitigation should occur as near to the project as
possible, certainly within the same watershed.
Because of the high interest from residents in both Swannanoa and Fairview about
this proposal, the serious concerns about water quality issues, and the unanswered
questions about the impact of the golf course within this application, we request
that the USACE and the NCDWQ delay action on the application and call a public
hearing. We believe that a public hearing is the best way to disseminate accurate
information to the public and to give residents, the developer, and other
interested parties an opportunity to be heard.
Thank you for your consideration of the issues raised in this letter. Please
contact me if you need further information.
Sincerely,
Rebecca Williams
Land Use Task Force, Swannanoa Pride Community Coalition
[e-mail]
828-686-3922
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