20180582 Ver 1_SAW-2016-00032 Comments and Request for Add Info_20180628

T0 DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
June 28, 2018
Action ID: SAW -2016-00032
C1earWater Environmental Consultants, Inc.
Attn.: Clement Riddle
32 Clayton Road
Asheville, NC 28801
Subject: Corps Comments and Request for Additional Information— Cashiers Lake Dredge and
Development Project
Dear Mr. Riddle:
Reference is made to your April 24, 2018, Department of the Army (DA) permit
application, submitted on behalf of Cashiers Canoe Club Development, LLC, for the Cashiers
Lake Dredge and Development Project in Cashiers, Jackson County, North Carolina. Based on
our review of the application, supporting documents, and comments submitted by supporting
agencies and the public, the Corps is requesting additional information and providing comments
as follows:
1. The Corps will require compensatory mitigation for the permanent impacts to
streams which result in a loss of waters of the U.S. (WoUS). The applicant is to
revise the proposed mitigation plan submitted with the application to include these
impacts. Also, submit N.C. Stream Assessment Method (NCSAM) worksheet and
data for the impacted stream reach(s).
2. The Corps advises the applicant to pursue alternatives to the proposed wetland
mitigation which would allow the required compensatory mitigation to be within the
Tugaloo subbasin. Specifically, comments obtained from Highlands -Cashiers Land
Trust (HCLT) stated the potential of a wetland resource in the Tugaloo subbasin
could be available for restoration and preservation. We recommend the applicant
contact HCLT to determine if this wetland resource is a viable option to meet the
required compensatory mitigation for wetlands. If so, then revise the proposed
mitigation plan accordingly. If not, provide a summary detailing why the resource
will not work for wetland mitigation.
3. The applicant request the permit to be valid for a length of 25 years. Upon issuance
the permit will be conditioned, during the first 5 -years all authorized impacts
associated with the resort hotel, residential community, and the initial dredge
activities are to be completed.

The work authorized will include periodic maintenance dredging which can be
performed for 25 years from the date of issuance. The applicant will notify the Corps
in writing at least two weeks before they intend to undertake any maintenance
dredging. The notice to the Corps will state the proposed area to be dredged and
method for dredging. The location and method for disposal of dredge material will
be in strict accordance with that authorized by the issued permit.
4. If future maintenance dredging activities involve permanent impacts to WoUS which
result in a loss of WoUS beyond those authorized, then these impacts will be
cumulative and could require compensatory mitigation. The applicant will submit a
request to modify the issued permit to account for these impacts and/or mitigation.
5. The applicant will submit to the Corps a request for jurisdictional determination
every 5 years from the date of permit issuance. The area for the request is to include
Cashiers Lake and the dredge spoil disposal area(s) including approximately 50 feet
from the edge of the lake and disposal area(s).
6. The applicant is to submit documentation to the Corps and DWR from Tuckasegee
Water and Sewer Authority (TWSA) which states TWSA currently has the capacity
for the proposed sewer inflows which are to be sent to their Cashiers facility; this
facility, as currently operated, can handle the increased inflows; and the increase in
the inflows will not change/alter/modify the current limits, guidelines, parameters, or
standards to the National Pollutant Discharge Elimination System (NPDES) Permit
for this facility.
7. Provide development details and plans (lot layout, roads, utility corridors, parking
areas, location of buildings, etc.) for the resort hotel and residential community areas
of the proposed project.
8. Provide details for dredge spoil disposal area(s) (erosion control practices,
vegetation cover, dewatering controls, containment methods/structures,
grading/slope controls. etc.).
9. Use of high-density polyethylene (HDPE) pipe which does not allow stream
substrate to accumulate and prohibits or significantly reduces movement of aquatic
organism will not be allowed for stream crossings.
10. Provide details of how the lake will be drawn -down for dredge activities and how
downstream flows below the dam will be maintained during draw -down, lake
refilling, dredging, and how flood flows will be managed during dredging.
11. In order to improve downstream water temperatures below the dam installation of a
cold water release/outflow device in Cashiers Lake will be required. Provide details
for this device/structure and outline operating procedures for this device.
12. Provide details of the characteristics and composition of the materials to be dredged,
including sampling data to determine the potential presence of regulated
pollutants/contaminants.

13. The applicant is to copy the Corps in their responses/submittals to the request for
additional information from DWR.
Please submit comments and the requested additional information by August 31, 2018. At
this time, the application is on hold until the above additional information has been received.
Once the Corps receives the information we will be able to continue to process your application.
If you have any questions please contact me.
Sincerely,
David Brown, PG
Regulatory Specialist/Geologist
Asheville Regulatory Field Office
Copy:
USFWS
Attn.: Byron Hamstead
160 Zillicoa Street
Asheville, NC 28801
NCDEQ-DWR
Attn.: Kevin Mitchell
2090 U.S. Highway 70
Swannanoa, NC 28778
NCDEQ-DWR
Attn.: Sue Homewood
450 W. Hanes Mill Road, Suite 300
Winston Salem, NC 27105
NCWRC
Attn.: Andrea Leslie
645 Fish Hatchery Road
Marion, NC 28752