20180582 Ver 1_Comments to USACE_20180606

Water Resources
Environmental Quality
June 6, 2018
ROY COOPER
Gomm),
MICHAEL S. REGAN
SectrMn
LINDA CULPEPPE-R
/moil Oir,z rnr
Corps Action ID# SAW -2016-00032
DWR# 20180582
Jackson County
David Brown
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Ave, Room 208
Asheville, North Carolina 28801-5006
Subject Project: Cashiers Canoe Club Development and Dredging Project
Dear Mr. Brown:
On behalf of the NC Division of Water Resources, we respectfully request that you consider the
following comments within your review of the 404 Individual Permit request for the above
referenced property:
1. The Division requests that the Individual Permit for the initial dredging and impacts for
development infrastructure be approved to occur within 5 years.
2. The Division is concerned that future maintenance dredging may have the potential to
disturb wetlands that may establish within the lake and which should be subject to
mitigation. If the USACE issues the Individual Permit to allow for the maintenance
dredging over a 25 year period as requested by the applicant, the Division requests that
the Permittee be required to submit an updated jurisdictional determination and dredging
plan prior to all maintenance dredging activities. The Division also recommends that
mitigation be required for any future wetlands that are allowed to develop into a
functioning wetland within the 25 year time period. The Division further recommends
that no extensions be granted to this permit beyond 25 years.
The Purpose and Need for the dredging portion of this project does not clearly detail why
the applicant cannot make sufficient use of their property without impacts to the
wetlands or with a reduced impact to wetlands.
4. The applicant has not provided a detailed Alternatives Analysis or a detailed avoidance
and minimization plan for the development portion of the proposed project.
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center � Raleigh, North Carolina 27699-1617
919 807 6300

Cashiers Canoe Club Development, LLC
Corps Action ID# SAW -2016-00032
DWR# 20180582
Page 2 of 2
5. The applicant has not provided a detailed Purpose and Need or an avoidance and
minimization analysis for the proposed bulkheads.
6. The development impacts for this project are conceptual; the Division recommends that
any approval be contingent upon a defined schedule for development activities.
7. The Division requires mitigation for all wetland impacts, the applicant has not submitted a
sufficient mitigation plan to the Division.
8. The proposed project is required to secure an approved Sediment and Erosion Control
Plan for the dredging activities, as well as all spoil locations. In addition, the project is
subject to the Trout Buffer as regulated by the Division of Energy and Mineral Resources.
9. The applicant should provide a detailed analysis and proposal for protection of
downstream water quality and quantity during dredging activities.
10. The Division has requested additional technical information from the applicant and
requests that the USACE also consider the attached letter during the review of the
application.
Thank you for your considering the Division's comments during your review of this Individual
Permit. If you have any questions, please contact Sue Homewood at 336-776-9693 or
[e-mail].
Sincerely,
Karen Higgins, Supervisor
401 & Buffer Permitting Branch
cc: Clement Riddle, ClearWater Environmental (via email)
Andrea Leslie, NCWRC (via email)
DWR ARO
DWR — Wetlands and Buffer Permitting Branch
Filename: 180582CashiersCanoeClub(Jackson)_404Comments