20171209 Ver 1_Letter to Division of Water Resources_20171117

November 17, 2017
Division of Water Resources
401 & Buffer Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
To Whom It May Concern
TOWN OF LAKE LURE
Lake Operations Department
On October 26, 2017, the Town of Lake Lure received a Request for Additional Information regarding a
submitted application for shoreline stabilization. The letter was dated October 26, 2017. The original
application was made as part of Lake Lure's inclusion in the GP 30. The letter specifically outlined the
deficiencies of the current application and the additional information needed. The additional information
is provided in the following paragraphs:
1) According to the information request, based on our application, the total linear feet of proposed
shoreline stabilization exceeds the 500 feet threshold for a USACE GP 30. As a result the Town was
instructed to submit a PCN for a Nationwide 13. The Town has submitted the PCN for the NW 13 to the
USACE and NC Wildlife. Copies of this application are enclosed with this letter for consideration, in
accordance with the additional information request. The Town was told that no additional fees would be
required for submittal based on the fee that had been previously submitted as part of the original
application.
2) The type of seawalls shown in the plans submitted with the original application do not meet the
standards outlined in the Duke Energy Shoreline Management Guidelines in that they are not dry -stacked
boulder walls, but rather are poured masonry walls. This is due to the fact that these walls are in fact
structural retaining walls that have been designed by astructural engineer and are critical structures in
preventing upland slope movement. The design calls for the installation of Class B rip rap at the toe of
these walsl and up the face in order to dissipate wave action, which is critical to protecting the wall as
well as reduce shoreline erosion to adjacent properties. The sites where these walls are called for in our
application already have seawalls in place and have been inspected by NC DWR Environmental
Specialists who have confirmed that they will accept these engineered designs as it pertains to this
particular application.
3) Our original application stated that Class C rip rap would be used for shoreline stabilization which
does not follow the recommendations of the Duke Energy Shoreline Management Guidelines. This was
in fact a mistake on the application and the desire of the Town is to follow the recommended guidelines
as closely as possible where applicable. Therefore we would amend our application to reflect the use of
Class B rip rap, in accordance with the recommended guidelines.
4) Additional information was requested regarding quantity of vegetation to be removed in the trout
buffer and a planting plan for re-establishment. With the exception of two of the projects described in the
P. O. Box 255, Lake Lure, NC 28746 & Phone [phone], Ext. 502, Fax [phone]

application, there will be no trout buffer impacts, as all the work will be done from the water. As such no
vegetation will be removed nor require replacing. The two projects where replacement of seawalls is
proposed, one project (Camp Lurecrest Ministries), the work will not remove any woody vegetation
because there is none there currently. This particular area is a high use area where campers congregate
and participate in various water activities, so there is no expectation of removing any additional
vegetation other than what temporary disturbance there will be in removing the existing wall. The area
upland of the wall is currently a grassy area and the desire is for it to remain as such to ensure access to
the water. The second wall project (Stokes) does have an intact trout buffer with substantial woody
vegetation. Some vegetation may need to be removed to make the necessary wall replacements, but the
removal will be limited to vegetation that is immediately adjacent to the wall, consisting primarily of
shrubs. Any removal of vegetation beyond what is necessary to perform the work will require approval
from the Town of Lake Lure as part of our local regulations as well as a trout waiver from NC DEMLR,
and will require a re -vegetation plan in accordance with the EEP's Guidelines for Riparian Buffer
Restoration. It is not anticipated that a re -vegetation plan will be necessary based on the desire of the
upland property owner to be in full compliance with all regulations.
It is the desire of the Town of Lake Lure to comply with all applicable rules and regulations and we hope
that this response is reasonable to provide the additional information requested. If you have any questions
about any of the revisions, please let me know. You can contact me at [phone] ext. 502 or at
[e-mail].
Thanks,
Clint Calhoun, CFM, CLM
Environmental Management Officer
Town of Lake Lure
Enclosures
P. O. Box 255, Lake Lure, NC 28746 * Phone [phone], Ext. 502, Fax [phone]