20180582 Ver 1_More Info Requested_20180606

ROY COOPER
Gorornor
MICHAEL S. REGAN
LINDA CULPEPPER
In w/ Dir'eclor
Water Resources
Lncironmcnml Quality
June 6, 2018
DWR # 20180582
Jackson County
Cashiers Canoe Club Development, LLC
Attn: Roseanne Giordani
PO Box 300849
Austin, TX 78703
Subject: REQUEST FOR ADDITIONAL INFORMATION
Cashiers Canoe Club Development and Lake Dredging
Dear Ms. Giordani:
On April 26, 2018, the Division of Water Resources — Water Quality Programs (Division) received
your application dated April 24, 2018, requesting an Individual Water Quality Certification from
the Division for your project. The Division has determined that your application is incomplete
and cannot be processed. The application is on -hold until all of the following information is
received:
1. Provide a detailed purpose and need for lake dredging. This should include an analysis of
what activities are unable to occur if the wetlands are not impacted, and whether the
activities could be practically accomplished if the wetland impacts are reduced. [15A
NCAC 02H .0506(b)]
2. Provide a schedule for the construction of the proposed development (subdivision, hotel,
parking area, and associated amenities). [15A NCAC 02H .0506(b)]
3. Provide a purpose and need for the bulkheads, including impacts #2, #3, #5, #9, and #11.
Also provide a detailed avoidance and minimization analysis for the bulkheads. [15A
NCAC 02H .0506(b)]
4. The jurisdictional determination submitted with the application indicates that there
are/were out parcels that were not delineated, specifically an out parcel between wetland
3 and wetland 5 that may have additional jurisdictional features. Please locate all
wetlands, streams, and other waters of the state as overlays on a detailed site plan. This
should include all areas identified as jurisdictional by the USACE within the project
boundary. Also clearly locate the Chattooga River where it is immediately adjacent to the
project boundary. [15A NCAC 02H .0502]
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919 807 6300

Cashiers Canoe Club Development, LLC
DWR#f 20180582
Request for Additional Information
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5. Please note that in accordance with 15A NCAC 02H .0500, the Division requires mitigation
for all impacts greater than 1 acre of wetlands. Your proposed total wetland impacts for
this project are 6.96 acres. You propose in your application to mitigate for impacts by
payment to the Division of Mitigation Services (DMS). Provide an acceptance letter from
DMS indicating acceptance of 6.96 acres of wetland mitigation.
6. Provide more details regarding avoidance and minimization for impact #13. The
application does not discuss what the purpose of the parking area and building is
for. Revise the plans to minimize the impacts or provide a detailed explanation of why
this plan for the activity cannot be practically accomplished, reduced or reconfigured to
better minimize disturbance to the wetland. [15A NCAC 02H .0506(f) and (g)]
7. Provide more details regarding avoidance and minimization at impact #6, #7, and
#8. Show all existing access roads/driveways/culverts for the existing development and
homes within this area on the plans. Provide a detailed explanation of why the
development layout/design cannot be practically accomplished, reduced or reconfigured
to better minimize disturbance to the streams and/or wetlands. [15A NCAC 02H .0506(f)
and (g)]
8. Provide a site plan with the proposed development and lot layout as an overlay including
jurisdictional features. Provide building envelopes for all lots with wetlands, streams or
trout buffers and stormwater setbacks on the site plans to demonstrate these lots are
able to be developed without additional jurisdictional impacts. Please be advised that
deed notifications or other legal language that clearly indicates to future owners that
there are jurisdictional features and that some lots may not be buildable as planned
without impacts that may not be approved by the regulatory agencies will be a condition
of the 401 Water Quality Certification. [15A NCAC 02H .0502(g)]
9. Clarify whether the Division of Energy, Mineral and Land Resources will require riprap
within any stream channels or wetlands as part of the Erosion & Sedimentation Control
Plan approval (including temporary impacts from lake dewatering discharge). If riprap is
required, enumerate and clearly label the temporary and permanent impacts on the site
plan and submit a channel restoration detail. Riprap must be located below the stream
bed elevation. [15A NCAC 02H .0506(f) and (g)]
10. Enumerate all wetland and stream impacts including but not limited to fill slopes/
dissipater pads/temporary dewatering impacts on the site plan and clearly label impacts.
The Division recommends highlighting by hatching or shading all permanent and
temporary impacts. [15A NCAC 02H .0502(g)]
11. Provide a detailed engineering plan, profile view, and cross-section of all proposed
culverts. These drawings must include details regarding stream alignment in relation to

Cashiers Canoe Club Development, LLC
DWR# 20180582
Request for Additional Information
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pipe alignment, pipe slope, pipe burial, and dissipater pad. Provide cross section details
that clearly show the provisions for aquatic life passage. [15A NCAC 02H .0502(b)]
12. Provide details on how you are going to maintain the physical integrity of the stream
above and below the culvert where multiple culverts are proposed. Where multiple pipes
or barrels are required, they shall be designed to mimic natural stream cross section as
closely as possible including pipes or barrels at flood plain elevation and/or sills where
appropriate. Widening the stream channel should be avoided. Stream channel widening
at the inlet or outlet end of structures typically decreases water velocity causing sediment
deposition that requires increased maintenance and disrupts aquatic life passage. A
construction sequence and detail should be provided to ensure the contractor is clear on
construction of these benches. [15A NCAC 02H .0506(b)(2)]
13. The stream impact length should be measured along the centerline of the stream. When
proposing a culvert, the impact length is generally greater than the length of the culvert
and associated dissipater since the existing stream usually has some sinuosity (curvature).
Verify that stream lengths have been surveyed or are otherwise accurate or provide
updated impact lengths. [15A NCAC 02H .0502(b)]
14. All development within this project is subject to 15A NCAC 02H .1021. Provide
documentation of an approved stormwater permit issued by the Division of Energy,
Mineral and Land Resources for all proposed built upon areas.
15. The application states that increased turbidity "may occur' as a result of the proposed
project. Due to the sensitivity of downstream waters, provide a detailed contingency plan
for large and/or prolonged precipitation events. Please note that duplicity and/or
oversight should be addressed if the plan relies on mechanical equipment for downstream
water quality protection and/or routine erosion control measures. Due to the sensitivity
of downstream waters the Division requests that an approved Erosion Control Plan be
secured prior to issuance of a 401 Certification. [15A NCAC 02H .0502(b)(3)]
16. Provide a lake dredging plan that clearly indicates how downstream water levels will be
continuously sustained during dredging and during refilling of the lake. Please note that
duplicity and/or oversight should be addressed if the plan relies on mechanical equipment
for continuous minimum flow. 15A NCAC 02H .0506(d)]
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. Please respond in writing within 30
calendar days of receipt of this letter by sending all of the above requested information through
this link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note that the DWR#
that is requested on the link is referenced above) or by sending one copy of all of the above
requested information to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh,
NC 27699-1617.

Cashiers Canoe Club Development, LLC
DWR# 20180582
Request for Additional Information
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If all of the requested information is not received in writing within 30 calendar days of receipt of
this letter, the Division will be unable to approve the application and it will be returned. The
return of this project will necessitate reapplication to the Division for approval, including a
complete application package and the appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for
this activity and any work done within waters of the state may be a violation of North Carolina
General Statutes and Administrative Code.
Please contact Sue Homewood at 336-776-9693 or [e-mail] if you have any
questions or concerns.
Sincerely,
Karen Higgins, Supervisor
401 & Buffer Permitting Branch
cc: Clement Riddle, ClearWater Environmental (via email)
David Brown, USACE Asheville Regulatory Field Office (via email)
Andrea Leslie, NCWRC (via email)
DWR ARO 401 files
DWR 401 & Buffer Permitting Unit
Filename: 180582Cash iersCa noeClu b(Jackson)_IC_H OLD