20180765 Ver 1_USFWS Comments_20180703

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FTM &AVTLIHIFE
United States Department of the InteriorSERVIUE
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa StreetFl
Asheville, North Carolina 28801
July 3, 2018
David Brown
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
Dear Mr. Brown:
Subject: High Hampton Redevelopment Project; Jackson County, North Carolina
Log No. 4-2-18-183
The U.S. Fish and Wildlife Service (Service) has reviewed the information provided in the public
notice issued June 15, 2018 for the project referenced above. We submit the following
comments in accordance with the provisions of the Fish and Wildlife Coordination Act, as
amended (16 U.S.C. 661-667e); the National Environmental Policy Act (42 U.S.C. §4321
et seq.); and section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C.
1531-1543) (Act).
Project Description
According to the information provided, High Hampton Resort, LLC is seeking authorizations to
permanently impact 3,293 linear feet of stream, 0.76 acres of wetland, and 0.159 acre of open
water associated with redesign of and existing golf course, roadway construction associated with
an additional 243 residential lots, streambank stabilization, beach construction, and the
construction of a laundry/maintenance facility. The proposed project is located on an existing
684 acre resort, golf course, and residential subdivision near Cashiers, North Carolina.
The proposed project occurs on the Highlands -Cashiers plateau. This area is typified by
regionally unique geologic formations (quartz diorite to granodorite, and biotite gneiss),
regionally unique climate (temperate oceanic [Cfb]), and contains elevations up to 4,930 feet
above MSL. These conditions support unique communities including mountain bogs and high
elevation granitic domes that provide habitats for several rare and/or endemic species. These
communities occur onsite in addition to oak -pine heath forests, forested headwater wetlands, and
stream/riparian habitats. Onsite habitats span across a wide range of elevations (3,600 — 4,618
feet).
The project drains into the Horsepasture River (Seneca subbasin) as well as the Chattooga River
(Tugaloo subbasin). Reaches of both the Chattooga and Horsepasture Rivers are classified as an
Outstanding Resource Water and are designated Wild and Scenic Rivers.

Federally Protected Species
Service records indicate a mist net capture of the federally threatened northern long-eared bat
(Myotis septentrionalis) in the proposed project vicinity. During site visits, the Service observed
high quality summer roosting habitat among the mature forests along the lower slopes of the
Chattooga Ridge. Adjacent streams and wetlands may provide suitable insect forage, and
adjacent lithic features may provide suitable overwintering habitat. The federally endangered
gray bat (Myotis grisescens) and Indiana bat (Myotis sodalis) may also utilize these habitats,
although we have no records of these species in the immediate project vicinity. We are
concerned about proposed impacts within and adjacent to the Chattooga Ridge associated with
the development of additional residential lots, roadways, and appurtenant infrastructure. Areas
along the Chattooga Ridge should be thoroughly evaluated for the presence of suitable
overwintering habitats for these species (i.e. rock outcrops and subterranean caves). The Service
may be available to assist in this evaluation.
According to the information provided, potential habitats for the federally threatened small
whorled pogonia (Isotria medeoloides) and swamp pink (Helonias bullata) exist onsite. Small
whorled pogonia typically grows in open, dry deciduous forests and areas along streams with
acidic soil. This species is also known to occur in rich, mesic forests associated with
rhododendron and white pine. Swamp pink occurs in mountain bogs, wetlands, along small
streams and meadows, and in spring seepage areas. It requires constantly saturated, but not
flooded forest habitat. This species often grows on hummocks formed by trees, shrubs, and
sphagnum moss.
In order to inform effect determinations to listed species, the proposed project should be
evaluated for potential impacts to the species above and other federally protected species that
occur in Jackson County (list attached). The methods of biological evaluation, survey locations,
survey results, and biological conclusions for each species should be summarized in a report and
submitted to this office for review. We require this information before we can concur with an
effect determination.
Several accounts of federal species of concern' (FSC) and/or priority species occur in or adjacent
to the proposed project. These species include: green salamander (Aneides aeneus, FSC),
yellowfin shiner (Notropis lutipinnis), divided -leaf ragwort (Packera millefolium, FSC),
Southern Appalachian purple pitcher plant (Sarracenia purpurea var. montana, FSC), granite
dome goldenrod (Solidago simulans, FSC), and bigtooth aspen (Poplulus grandidentata, unique
glacial relict). We offer the following comments in the interest of protecting these species and
other natural resources:
Compensatory Mitigation
The Applicant proposes to provide onsite preservation of 23,355 linear feet of stream (7.5:1) and
onsite preservation of 21.645 acres of wetland (30:1). The information provided indicates that
onsite stream preservation areas would be protected with a 30 -foot -wide riparian buffer on each
side of the stream, and this buffer would be maintained under conservation easement (held by
Highlands Conservancy). As it is difficult to discern the locations proposed for onsite
1 Federal species are not currently afforded legal protection under the Act, but incorporating proactive conservation
measures on their behalf may preclude the need to list them in the future.
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preservation based on the information provided, we request that the Applicant outline these
locations (preferably via GIS compatible files), and provide this office with a copy of the final
draft conservation easement when it becomes available.
In addition to streams, wetlands designated for onsite preservation should also have buffers held
under conservation easement. To maintain ecological function of adjacent waters, forested
riparian and wetland buffers should be as wide as possible, but should be a minimum of 50 feet
wide along intermittent streams and 100 feet wide along perennial streams and wetlands.
Impervious surfaces, ditches, pipes, roads, utility lines (sewer, water, gas, transmission, etc.), and
other infrastructure that require maintained, cleared rights-of-way and/or compromise the
functions and values of the forested buffers should not occur within these buffer areas. Signage
should demarcate buffer and preservation areas (especially play -over areas and areas with
relatively "high traffic") to ensure that they are not impacted.
As proposed, mitigation for an additional 2,806 linear feet of stream impacts would be provided
at a 1:1 ratio via North Carolina Division of Mitigation Services In -Lieu fee program. Effective
July 1, 2018, the NCDMS fee schedule for stream mitigation increased significantly. We request
that the Applicant pursue alternatives to avoid these proposed stream impacts, and/or ensure that
compensatory mitigation stays within the Highlands -Cashiers Plateau due to the unique
characteristics of the area and the high quality aquatic habitats of the project's receiving waters.
Hand Clearing
The Applicant proposes to hand clear vegetation up to twice per year at three wetland areas.
Vegetation would be limited to less than six feet in height at these locations to accommodate golf
play -over. According to the information provided, it appears that most or all of the hand -
clearing areas are within proposed conservation easement areas. Priority wetland plants occupy
one or more of the areas designated for hand clearing. We request that the Applicant describe in
detail the proposed hand clearing activities, and provide us with this information for review.
Specifically, we request information that specifies the minimum vegetation height, clearing
methods, proposed materials that would be used (herbicide applications, etc.), and the
responsible party (Applicant or Highlands Conservancy). As applicable, criteria for hand
clearing in these areas should be referenced in the terms of the proposed conservation easements.
Site Irri - ag tion
The Service is concerned that the proposed Hampton Lake withdrawal for irrigation may impact
adjacent occurrences of Southern Appalachian purple pitcher plant and wetland habitats
proposed for protection under conservation easement. We request that the Applicant establish a
plan for lake withdrawal and irrigation that establishes a minimum pond elevation and drawdown
duration in order to maintain hydrologic conditions that are protective of adjacent wetlands and
the natural resources supported therein.
Chattooga Ridge Development
The Service is concerned with the impacts associated with proposed construction of residential
lots and associated infrastructure (e.g. roadways and stormwater) at the top of Chattooga Ridge
and along its toe. Our records show an occurrence of divided -leaf ragwort (Packera millefolium,
FSC) that occurs within the proposed impact area at the top of Chattooga Ridge. We are
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concerned about impacts to this species as well as indirect impacts to adjacent habitats held
under conservation easement. We encourage the Applicant to omit or reduce development
activities in this area in the interest of protecting these unique habitats (high elevation granitic
dome) and the natural communities that they support.
Wastewater Infrastructure
According to the information provided, future wastewater needs from the project (excluding
treatment from proposed on -lot systems) would total 74,469 gallons per day. Treatment of this
additional wastewater would be partially managed by a proposed onsite wastewater treatment
system (50,000 gallons per day capacity). The remaining wastewater would be treated by a new
wastewater treatment plant proposed to be operational in 2021 (managed by the Tuckasegee
Water and Sewer Authority). We believe the Applicant is referencing a proposed TWSA plant
that would discharge into the Horsepasture River.
To evaluate potential indirect effects from the proposed project's wastewater needs, we request
that the Applicant provide the following information regarding the TWSA plant referenced in the
application materials: 1) its proposed location and receiving waters; 2) the plant design capacity;
and 3) a description of project -mediated impacts (if any) associated with tying into this plant.
Impervious Surfaces and Low -Impact Development
Stormwater control measures were not detailed in the information provided. The Service is
concerned about the proposed increase in impervious surface and stormwater-mediated impacts
to receiving streams and wetlands, and to existing/proposed areas under conservation easement.
We request that the Applicant provide a stormwater control plan that effectively manages for the
quantity and quality of project -mediated stormwater runoff.
We recommend the use of low -impact -development techniques, such as reduced road widths,
grassed swales in place of curb and gutter, rain gardens, and wetland retention areas, for
retaining and treating storm -water runoff rather than the more traditional measures, such as large
retention ponds, etc. Since the purpose of storm -water -control is to protect streams and
wetlands, no storm -water -control measures or best management practices should be installed
within any stream (perennial or intermittent) or wetland. We also recommend that consideration
be given to the use of pervious materials (i.e., pervious concrete, interlocking/open paving
blocks, etc.) for the construction of roads, driveways, sidewalks, etc. Pervious surfaces minimize
changes to the hydrology of the watershed and can be used to facilitate groundwater recharge.
Pervious materials are also less likely to absorb and store heat and allow the cooler soil below to
cool the pavement. Additionally, pervious concrete requires less maintenance and is less
susceptible to freeze/thaw cracking due to large voids within the concrete.
Road Crossings
According to the information provided, permanent impacts to 546 linear feet of stream and 0.061
acre of wetland would result from proposed road crossings. We request that the Applicant
consider the use of spanning bridges for all proposed stream and wetland crossings. As
proposed, all cart path crossings of streams would be made via bridges. Bridges should be
designed and constructed so that no piers or bents are placed in the stream, approaches and
abutments do not constrict the stream channel, and the crossing is perpendicular to the stream.
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Spanning some or all of the floodplain allows the stream to access its floodplain and dissipate
energy during high flows and also provides for terrestrial wildlife passage. When bank
stabilization is necessary, we recommend that the use of riprap be minimized and that a
riprap-free buffer zone be maintained under the bridge to allow for wildlife movement. If fill in
the floodplain is necessary, floodplain culverts should be added through the fill to allow the
stream access to the floodplain during high flows.
Where bridges and bottomless culverts are not possible and traditional culverts are the only
feasible option, the culvert design should provide for a minimum water depth in the structure
during low-flow/dry periods. Sufficient water depth should be maintained in all flow regimes so
as to accommodate both the upstream and downstream movement of aquatic species. Water
depth inside the culvert must be adequate for fish to be completely immersed and all other
aquatic life to move freely. Culverts should be designed and installed at the same slope as the
stream grade to maintain an acceptable water velocity for aquatic life passage and for stream
substrate characteristics to be retained within the culvert.
Erosion and Sediment Control Measures
Measures to control sediment and erosion should be installed before any ground -disturbing
activities occur. Instream work should occur under dry conditions utilizing a temporary
diversion/pump-around system wherever possible. Grading and backfilling should be
minimized, and existing native vegetation should be retained (wherever possible) to maintain
riparian cover. Disturbed areas should be revegetated with native grass and tree species as soon
as the project is completed. Ground disturbance should be limited to what will be stabilized (via
mulch, matting, etc.) by the end of the workday. Natural fiber matting (coir) should be used for
erosion control as synthetic netting can trap animals and persist in the environment beyond its
intended purpose.
The Service appreciates the opportunity to provide these comments. Please contact Mr. Byron
Hamstead of our staff at 828/258-3939, Ext. 225, if you have any questions. In any future
correspondence concerning this project, please reference our Log Number 4-2-18-183.
Sincerely,
- - original signed - -
Janet Mizzi
Field Supervisor
e.c. Kevin Mitchell; NCDWR
Sue Homewood; NCDWR
Andrea Leslie; NCWRC
Clement Riddle; C1earWater Environmental Consultants, Inc.
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