21080765 Ver 1_WRC Comments_20180716

n North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
July 16, 2018
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: High Hampton Redevelopment Project
Fowler Creek, unnamed tributaries, and wetlands, Jackson County
SAW -2017-02281
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the
individual 404 permit application for the High Hampton Redevelopment Project, which proposes
to permanently impact 3,293 ft of stream, 0.76 acre of wetland, and 0.0159 acres of open water,
as well as temporarily impact 200 ft of stream in Jackson County. NCWRC biologists have
visited the site multiple times. Our comments on this application are offered for your
consideration under provisions of the Clean Water Act of 1977 (33 U.S.C. 466 et. seq.) and Fish
and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d).
High Hampton Resort, LLC/High Hampton Land, LLC on redeveloping the High Hampton
resort and residential community through the expansion of the residential community,
redesigning and expanding the golf course, and upgrading the resort core and associated
amenities. The project site is 684 acres, consisting of a residential subdivision, existing resort
core, golf course, and approximately 400 acres of undeveloped land. The undeveloped land is
largely forested, and it includes numerous priority habitats named in NCWRC's Wildlife Action
Plan, including bogs and other wetlands, rock outcrops, caves, and high elevation habitats. Apart
from two wetlands and stream buffers to be placed in a conservation easement, it appears that the
entirety of the undeveloped area would be developed into golf course, amenities, infrastructure,
and residential lots.
The project is planned over the next 10 years in the following phases:
1. Expand and reconfigure the golf course in 2018-2020, impacting 2,129 ft of Fowler Creek
and unnamed tributaries (UTs), 0.528 acre of wetland, and 0.009 acre of open water.
Streambank stabilization on 600 ft of stream is planned for 3 sites on the golf course, and it is
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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assumed that this work will be completed during the 2018-2020 timeframe. A water intake
would be placed on the existing lake for irrigation of the golf courses.
2. Construct resort and core amenities and northwest residential area and residential area west
of NC 107 in 2019-2021. Construct remaining residential areas in 2021-2028. The resort
core will involve 0.171 acre of wetland impact and 0.15 acre of open water impact. Utility
installation will involve 200 ft of temporary stream impact. A wastewater treatment plant
would be constructed that would treat wastewater from most of the residences and the resort
core; treatment would involve tertiary treatment and drip irrigation. The remaining
residences would be on individual septic systems.
3. Roads will involve 564 ft of stream impact and 0.061 acre of wetland impact, and it is
unknown when this work will be performed during the 10 -year timeframe.
The project site is approximately 3 miles upstream of the Chattooga River, which is an
Outstanding Resource Water and part of the Chattooga River Aquatic Habitat, a natural area
rated as Very High by the NC Natural Heritage Program due to the richness of rare species it
contains. The rare Yellowfin Shiner [Notropis lutipinnis, NC Special Concern (SC)] is found in
the UT to Fowler Creek that runs through the part of the site that is west of NC 107 as well as
Fowler Creek itself just downstream of the project site. In addition, NCWRC found wild Brook
Trout (Salvelinus fontinalis) in the watershed that feeds the lake; streams containing Brook Trout
include the main UT to Fowler Creek that enters the lake and a small UT that comes into the
large wetland from the northeast side; this latter stream runs through the proposed site of golf
Hole 17.
Numerous wetlands are present throughout the site. The two largest wetlands are bogs, one
upstream of the lake and the other on the west side of NC 107. Few large bogs remain on the
Highlands -Cashiers plateau, and these wetlands provide unique habitat for birds, amphibians,
and reptiles. A small bog is also present on the northern border of the lake, and it hosts a
population of Southern Appalachian Purple Pitcher Plant [Sarracenia purpurea var. montana,
US Federal Species of Concern (FSC), NC Significantly Rare (SR)].
The northeast portion of the project site falls within the High Hampton/Chattooga Ridge Natural
Area, rated as High by the NC Natural Heritage Program due to the richness of rare species and
exemplary natural communities on site. A conservation easement has been placed in parts of this
natural area, including some of the higher elevation areas of Rocky Mountain and Chimneytop
Mountain. NCWRC biologists surveyed the portion of the project site at the foot of Chattooga
Ridge, just outside the conservation easements. Numerous rock outcrops and subterranean caves
dot this area; this complex rock structure has good potential to serve as habitat for numerous rare
and common species, including Green Salamander [Aneides aeneus, US FSC, NC Threatened
(T), petitioned for federal listing], Timber Rattlesnake (Crotalus horridus, NC SC), and
mammals such as Southern Appalachian Eastern Woodrat (Neotoma floridana haematoreia).
Numerous bat species may also be associated with the caves and rock outcrops, including
Indiana Bat [Myotis sodalis, US Endangered (E), NC E], Northern Long-eared Bat [Myotis
septentrionalis, US Threatened (T), NC SR], Eastern Small -footed Bat (Myotis leibii, US FSC,
NC SC), Little Brown Bat (Myotis lucifugus, NC SR), and Tricolored Bat (Perimyotis subflavus,
NC SR).

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We offer the following comments on the 404 permit application:
• Stream impacts. We are concerned about the extent of proposed stream impacts from this
project, which include 3,293 ft of permanent and 200 ft of temporary impacts. We strongly
recommend that spanning structures, such as bridges and bottomless culverts, be used across
the site to minimize stream impacts.
o As noted above, the watershed that drains to the lake has wild Brook Trout streams.
We ask that the applicant re-evaluate their proposed impacts in this area. In
particular, we ask that direct impacts to known Brook Trout streams and their riparian
areas be eliminated and offer the following recommendations to do so: (1) Hole 17
should be redesigned to avoid Stream Impact 6 (269 ft of culvert), associated
wetlands (Wetland Impacts 3, 4, and 5), and riparian buffer on the UT, (2) road
culverts associated with Stream Impacts 7, 9 and 10 (totaling 134 ft of culvert) should
be converted to bridges, and (3) riparian buffer clearing should be avoided in the far
eastern area identified for hand -clearing of vegetation. Due to the presence of Brook
Trout in this area, any in -stream work on streams within the watershed of the lake
will need to be performed outside of the Brook Trout moratorium of October 15 to
April 15 in order to minimize impacts to trout spawning.
o Stream Impact 18 is a bedrock -bottomed stream that connects a large off-site bog to
the large western bog on-site. We strongly recommend that this culvert be replaced
with a bridge, as it will be very difficult to install a passable culvert on bedrock.
o Any in -stream work for temporary and permanent impacts within the lake's
watershed should be avoided during the Brook Trout moratorium of October 15 to
April 15 to minimize impacts to spawning.
o No detailed information is provided on how streams will be impacted. Culverts must
be sized to pass storm events and embedded to allow substrate retention and aquatic
organism passage. We recommend against using slick -bottomed HDPE culverts, as
this material is less likely to hold stream substrate and provide for movement of
aquatic organisms like fish and salamanders. Work should be performed in the dry.
o Three sites in golf course areas are proposed for stream stabilization, but no
information is provided on the method. We request details on stabilization methods.
We strongly recommend that bioengineering methods be used and woody native
vegetation be used to provide long-term bank stability and in -stream temperature
moderation.
o Ten sites are proposed for utility crossings. We recommend against the use of riprap
and ask that native seeding, matting, and native live stakes be used. In addition,
native substrate should be stockpiled and reused when restoring the stream bed to its
original contours.
• Erosion and sediment control. It is extremely important that excellent erosion and sediment
control be used for this project to protect wetlands and streams on site. For any disturbance
within the watershed of the eastern bog complex and Brook Trout population, we request the
use of sediment and erosion control practices outlined in the Design Standards in Sensitive
Watersheds (15A NCAC 4B .0124). Disturbed areas should be seeded, mulched and/or
matted as soon as possible, preferably at the end of each work day; at a minimum, disturbed

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areas should be stabilized within five working days or seven calendar days, whichever is
shorter.
• Wetland impacts. 0.76 acre of permanent impacts is proposed for this project. Most of this
impact is on small wetlands, and the larger bog areas will be largely avoided. Hand clearing
of woody vegetation to limit vegetation to less than 6 ft in height is proposed for the small
bog on the northern edge of the lake and for the central area and eastern arm of the large
northeast bog. Any hand clearing must be done with utmost care, avoiding the use of
herbicides and heavy machinery within the wetland areas.
• Irrigation intake and lake outflows. The applicant proposes to install an intake within the
lake to irrigate the golf course. The withdraw rate would be <0.5 ft/sec, and the applicant
will use 74,000-90,000 gpd when needed during the summer months. The applicant
estimated the 7Q10 flow for the lake at 0.475 cfs and proposes to maintain a minimum flow
of 61,400 gpd from the dam, which is 80% of the 7Q10, during drought conditions.
o We prefer that incoming flows equal outgoing flows to maintain natural hydrology in
downstream Fowler Creek. However, we appreciate efforts to maintain a minimum
flow, and we recommend that a minimum flow of at least the 7Q10 be maintained at
all times.
o Explain if the withdrawal of 74,000-90,000 gpd is a constant rate (e.g., cfs) or if this
amount is to be withdrawn during a concentrated portion of the day. If the latter,
please provide the withdrawal rate in cfs.
o We strongly recommend that water -saving measures be used to lessen the need for
irrigation from the lake.
o Please state if this is the only withdrawal from the lake or if it adds to a current
irrigation withdrawal.
o Please define "drought conditions."
• Miti ag tion. Wetland mitigation is proposed to consist of on-site preservation of 21.645 acres,
largely in the two large bog systems. We support the wetland mitigation proposed if a 50 -ft
buffer around these wetland systems is maintained. The applicant proposes to mitigate for
stream impacts with two means — mitigation through the NC Division of Mitigation Services
(NCDMS) at a 1:1 ratio, and on-site preservation of 23,255 ft of streams at a 7.5:1 ratio. On-
site preservation locations were not provided in the application materials, and we ask for this
information to evaluate this option. In addition, on-site preservation is proposed with a 30 -ft
riparian buffer. We ask that the riparian buffer be increased to a minimum of50 ft for these
streams.
The application proposes to acquire stream mitigation through the NC Division of
Mitigation Services, which may not have mitigation available in the Savannah River Basin
and would likely use mitigation from within the Little Tennessee River Basin. NCWRC
recommends that mitigation be provided within the Savanah River basin, preferably on the
Highlands -Cashiers plateau, an area with unique streams and wetlands, driven by geology,
climate, and faunal and floral characteristics.
• Wastewater treatment. The applicant proposes to treat most of residential sewage with a
proposed wastewater treatment system (WWTS) or the new Tuckasegee Water and Sewer
Authority's regional plant, which is yet to be constructed. The proposed WWTS would be a
drip irrigation system with tertiary treatment. We strongly recommend that tertiary treatment
be provided with UV light. The irrigation areas would include 11.25 acres, which would

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include a primary area and a buffer area for safety. It is unknown if these treatment areas are
forested or cleared; generally, drip irrigation treatment is just as successful within forested
areas. We also recommend that the applicant consider using the treated wastewater water on
the golf courses themselves.
Stormwater. No information on stormwater management from the site is provided in the
application, and we request that this information be provided. Effective stormwater
management is essential in minimizing impacts to downstream waters. Stormwater control
measures should mimic the hydrograph consistent with an impervious coverage of less than
10%. We recommend the use of Low Impact Design techniques, such as grassed swales and
pervious pavement; curb and gutter, catch basins, and underground piping of stormwater
should be avoided. As stormwater runoff from pavement can cause short-term temperature
spikes in downstream waters, mechanisms to lower stormwater temperature should be
incorporated into the stormwater management design.
As noted earlier, there are residential sites and roads planned for areas at the foot of Chattooga
Ridge. The area that runs along the western edge of the existing Rocky Mountain conservation
easement is often steep and has many rock outcrops and subterranean caves. The narrow far
eastern area between the two existing conservation easements is also steep, containing portions
of granitic dome and rock outcrops as well as cove forest and numerous stream/seep features that
appear to be unmapped. Although NCWRC staff did not visit the area that runs along the
western edge of the existing Chimneytop Mountain conservation easement, this area could also
harbor rock outcrops and caves. The entire area is part of the High Hampton/Chattooga Ridge
Natural Area, and we request that the applicant reconsider the plans for residential development
of this area. At a minimum, avoiding rock outcrops, caves, and granitic dome is recommended,
and we ask that tree clearing be avoided within 50 meters of these features to lessen impacts to
animals that use these special habitats. We also recommend reconsidering development of the
narrow area on the top of Chattooga Ridge, as it is also within the High Hampton/Chattooga
Ridge Natural Area and features high elevation rocky habitat and forest, both which may provide
habitat for Green Salamanders, Timber Rattlesnakes, and numerous bat species. We offer an on-
site meeting of these areas so that the applicant and NCWRC biologists can discuss possible
options to minimize impacts to these important habitats.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Clement Riddle, C1earWater Environmental Consultants
Kevin Mitchell & Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Lori Williams, Powell Wheeler, & Doug Besler, NCWRC

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