20180765 Ver 1_Response to USFWS comments_20181001

CLearWater
C1earWater Environmental Consultants, Inc.
October 1, 2018 www.cwenv.com
Mr. David Brown
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
RE: High Hampton Redevelopment Project
Response to USFWS Agency Comments
Jackson County, North Carolina
Action ID SAW -2017-02281; DWQ Project # 2018-0765
Dear Mr. Brown,
Please reference the letter dated July 3, 2018 (Attachment A) sent by the US Fish and Wildlife
Service (USFWS) in response to the permit application submitted by C1earWater Environmental
Consultants, Inc. (CEC), on behalf of High Hampton Resort, LLC (Applicant) represented by Mr.
Owen Schultz. The permit application requested written authorization for impacts associated with
the expansion and renovation of the existing High Hampton Resort, golf course, and associated
infrastructure. The comments provided by the USFWS are listed and discussed below.
FWS Comment #1— 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 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. "
Cavers/bat biologists from Skybax Ecological Services, LLC conducted a bat survey of the
High Hampton project area from July 23-25, 2018. Although the presence of small boulder
crawl-ins/crawl-throughs and rock shelters were present within the study area, none
provided suitable conditions for overwintering habitat for gray, Indiana, and/or Northern
long-eared bat. Furthermore, no evidence of roosting bats was observed. The bat habitat
survey is included as Attachment B.
32 Clayton Street
Asheville, NC 28801
828-698-9800 Tel

Mr. David Brown
10/1/2018
Page 2 of 8
"In order to inform effect determinations to listed species, the proposed project should be
evaluated for potential impacts to the species listed 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. "
A threatened and endangered species survey was conducted by CEC staff and botanist Ms.
Julie Smoak, from August -September 2017 and again on May 3-4, 2018 and July 13, 2018,
to determine the presence or absence of Federally listed species on-site. A Threatened and
Endangered Species Survey and Habitat Assessment Report was included within the
individual permit application as Appendix C. Potential suitable habitat for the bog turtle,
small whorled pogonia, and swamp pink were observed and evaluated during the survey,
however, no threatened or endangered species were identified within the project boundary.
Please reference FWS Comment #5 — Chattooga Ridge Development below for additional
information.
FWS Comment #2 - Compensatory Mitigation 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 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.
On-site preservation locations were indicated on the Stream and Wetland Impact Map
(Figure 5.0) included with the individual permit application. These areas are indicated by
a blue outline, denoted within the map legend as "stream buffer." A final draft conservation
easement will be provided to the US Army Corps of Engineers (Corps) and the USFWS
when it is 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.
The applicant has planned carefully to remove preserved wetlands, streams, and buffers
from individually held residential lots. As a result, lot sizes have been reduced and wetland
buffers are not proposed for this project. The on-site stream preservation plan proposed for
the project complies with The Mitigation Rule as outlined in the "Use of Stream

Mr. David Brown
10/1/2018
Page 3 of 8
Preservation as Compensatory Mitigation in North Carolina, North Carolina Interagency
Review Team, December 5, 2012." The minimum buffer width for stream preservation
within the mountains is 30 feet on both sides of the stream channel. Proposed stream
buffers for the project range from a minimum of 30 feet and extend to greater than 50 feet
in locations where feasible.
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.
Mitigation banks within the Savannah River watershed are unavailable. The proposed
mitigation plan combining payment to DMS and on-site preservation exceeds mitigation
requirements and will assist in protecting the watershed.
FWS Comment #3 - 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 golfplay-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.
Hand clearing and maintenance of the wetland areas at three locations will be conducted
by High Hampton Resort golf maintenance staff. Please note that the proposed hand -
clearing in wetlands is mostly comprised of vegetation that is already 3-4 feet tall, except
along the margins of the wetlands. The hand clearing management plan shall be conducted
as follows:
• Clearing is limited to four times per year, as needed
• Clearing will be done using tools such as sheers, clippers, loppers, and hand-
held gas -powered equipment
• No herbicides will be used in wetland areas
• Wetland vegetation maintenance for play -over at holes 16 and 17 will be
conducted to maintain shrubby vegetation at approximately 3-4 feet or
taller, stream play over on hole 17 will be at least 3-6 feet
• Wetland and stream vegetation maintenance for play -over at hole 18 will be
maintained between 1-3 feet
• Pre-existing turf conditions will be maintained at golf holes 2,5,7, and 8.
• Stream play over on hole 9 will be maintained at 3-6 feet

Mr. David Brown
10/1/2018
Page 4 of 8
A copy of this maintenance plan will be made accessible for employees and located on-site
in the maintenance facility building.
FWS Comment #4 — Site Irrigation - 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.
Anchor QEA calculated the 7Q10 flow for the outlet of Hampton Lake. The total area that
drains into the lake was estimated to be 0.757 square miles. Anchor QEA calculated the
mean annual flow to be approximately 3.028 cubic feet per (cfs) second (1,957,047 gpd).
Based on this information the 7Q10 for Hampton Lake is estimated to be 0.475 cfs. The
dam at High Hampton will be operated to allow a minimum of 61,400 gallons per day
(GPD) (80% of 7Q10) through the lake during drought conditions. CEC also permitted the
dam repair on Jewel Lake on February 6, 2008, which included the installation of a Cold-
water release siphon.
After additional analysis, it was determined that irrigation demands for the site could be
achieved with 57,000 GPD versus 61,400 GPD as originally proposed (approximately 2%
of mean annual flow). Hampton Lake is approximately 13 acres and contains
approximately 4,236,068 gallons of water within the top one foot of the lake. As result,
High Hampton could achieve 74 days of full irrigation needs at 57,000 GPD during drought
conditions, which would lower the lake by approximately one foot. This extreme example
also assumes that there is zero inflow of water into the lake. It should be noted that High
Hampton has been using Hampton Lake for irrigating the golf course for many years.
High Hampton is also in the process of preparing a design for a water control system for
Hampton and Jewell Lake. This design will include the installation of new electronically
controlled valves that will allow for maintenance of the water level in both lakes. Once this
device is permitted and installed, High Hampton could set a maximum draw down level
for the Iake at one foot below full pool elevation. It is unlikely that a temporary drawn
down during drought condition would adversely affect the population of Southern
Appalachian purple pitcher plants.
FWS Comment #5 - 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 concerned about impacts to this species as
well as 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.

Mr. David Brown
10/1/2018
Page 5 of 8
A threatened and endangered species survey was conducted by CEC and Ms. Julie Smoak,
a certified botanist, from August -September 2017 and again on May 3-4, 2018, to
determine the presence or absence of Federally listed species on-site. After receiving
requests for additional information from the US Fish and Wildlife Service and the Wildlife
Resources Commission, CEC and Ms. Smoak conducted a follow-up survey on July 13,
2018, with particular emphasis on the High Hampton/Chattooga Ridge Natural Area. One
occurrence of Packera millefolium (divided leaf ragwort) was documented approximately
10 feet outside of the project boundary along the western edge of the High
Hampton/Chimneytop Mountain conservation easement. No other occurrences of Packera
millefolium or other Federally endangered species were observed. An updated Threatened
and Endangered Species Survey and Habitat Assessment Report (updated July 13, 2018)
is included in Attachment C.
FWS Comment #6 — Wastewater Infrastructure - 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.
Only the existing wastewater capacity currently used from Tuckaseegee Water and Sewer
Authority (TWASA) will continue to be used for the High Hampton development. Current
usage based upon 15A NCAC 02T is 74,030 gallons per day. All future usage of
wastewater will be provided by the proposed wastewater treatment plant to be constructed
near the fieldstone section of the proposed High Hampton development. Phase 1 of the
wastewater treatment plant will provide 50,000 GPD of wastewater capacity to the
development. Phase 2 of the wastewater treatment plant will add an additional 50,000
gallons per day of capacity. The future 243 residential lots will have 75 lots served by on
lot individual sewer systems permitted one at a time by the developer prior to being
sold. The remaining 168 proposed residential lots will generate 24,864 gallons per day that
will be provided with sewer capacity by the developer's wastewater plant currently being
designed and permitted for 50,000 gallons per day. The resort core will generate a future
sewer need of 19,605 GPD. In addition, future employee housing will have a demand of
10,000 GPD. The proposed laundry and back of house will generate approximately 20,000
GPD of additional sewer usage daily. Therefore, the future development needs from either
the new development wastewater treatment system and/or TWASA plant will be 74,469
GPD not including on lot sewer systems.
The new wastewater treatment plant (WWTP) is a tertiary and land application system that
will utilize five drip irrigation fields located throughout the development. Mountain Soils,
Inc. (MSI) conducted an on-site subsurface wastewater effluent disposal feasibility study
on select properties owned by High Hampton Land, LLC and High Hampton Resort, LLC.
The properties were evaluated in accordance with North Carolina Statute G. S. 130A-
336.1, 15A NCAC 18A.1971 Engineered Option Permit (b). Review and approval of the
WWTP and land application is conducted by the N.C. Division of Public Health.

Mr. David Brown
10/1/2018
Page 6 of 8
Under the rules of the NC Department of Health and Human Services (DHHS), the
permitting of the wastewater treatment plant will be governed by § 130A-
336.1. Alternative Process for Wastewater System Approvals. A professional engineer
licensed under Chapter 89C of the General Statutes may, at the direction of the owner of a
proposed wastewater system who wishes to utilize the engineered option permit, prepare
signed and sealed drawings, specifications, plans, and reports for the design, construction,
operation, and maintenance of the wastewater system in accordance with this section and
rules adopted thereunder. The professional engineer designing the proposed wastewater
system shall use recognized principles and practices of engineering and applicable rules of
the Commission in the calculations and design of the wastewater system. The
investigations and findings of the professional engineer shall include, at a minimum, the
information required in rules adopted by the Commission pursuant to G.S. 130A -335(e).
The professional engineer may, at the engineer's discretion, employ pretreatment
technologies not yet approved in this State.
FWS Comment #7 — Impervious Surfaces and Low -Impact Development - 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.
The development will comply with N.C. ORW rules and provide stormwater treatment for
the project as required by 15A NCAC 02b .0225. A conceptual stormwater plan was
submitted with the individual permit application for some of the high-density development
areas of the project. WGLA Engineering will also submit the required stormwater plans for
the resort core area, new golf maintenance/back-of-house, and Phase 1 of the high-density
residential areas to NC Division of Energy, Mineral, and Land Resources (DEMLR) for
review and approval in 2018. Preliminary stormwater plans and calculations have been
prepared and space has been allocated for the proposed stormwater measures. Final plans
and calculations will be submitted once the soil investigation for these areas has been
completed and results incorporated into the design.

Mr. David Brown
10/1/2018
Page 7 of 8
Grassed water quality swales and other low-density stormwater measures may be utilized
in areas of the site where impervious surfaces are less concentrated. The low-density
residential area will not have curb and gutters. Areas that have been identified as high
density in the project include the resort core, the new golf maintenance facility/back of
house, and some of the denser residential areas. Stormwater runoff for these areas will be
collected via piping systems and swales and directed to various stormwater control
measures. These measures would include bioretention cells, permeable pavement,
rainwater harvesting, disconnected impervious surfaces, and possibly StormFilter or
BayFilter systems approved by DWR. The stormwater management plan will be approved
prior to impacts to streams.
FWS Comment #7 — 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.
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.
The Applicant has minimized impacts by proposing the installation of seven bridges for
roads and the use of bridges for the golf cart paths. Redesign of the site, including the
inclusion of bridges where feasible, has reduced total permanent stream impacts for the
entire project by an additional 40 percent, from 2,693 linear feet of stream as originally
proposed, to 1,613 linear feet of stream impact.
Culverts will be installed in accordance with NC Division of Water Quality (DWQ)
Certification 3890 (Condition 13) and any conditions imposed by the Corps. These
conditions include requirements to cross streams at perpendicular angles and provisions
for maintenance of stream dimensions.

Mr. David Brown
10/1/2018
Page 8 of 8
Bottomless culverts and bridges are exponentially more expensive than culverts and are
not cost effective for this project. For example, in this region, the cost of installation for a
typical 36 -inch culvert is approximately $5,000, the cost for a typical 36 -inch bottomless
culvert is approximately $150,000, and the cost of a typical bridge is approximately
$200,000.
FWS Comment #8 - 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 far erosion control as synthetic netting can trap animals and
persist in the environment beyond its intended purpose.
The sediment and erosion control plan for the site will be reviewed and approved by
DEMLR. The site will be in compliance with regulations and standards set forth by
DEMLR. Additionally, High Hampton will comply with the use of sediment and erosion
control practices outlined in the Design Standards in Sensitive Watersheds (15 NCAC
4B.0124). No work will begin on-site without an approved sediment and erosion control
plan.
The Applicant believes the information submitted in this package addresses all issues set forth by
the USFWS in the letter dated July 3, 2018. Should you have any questions or comments
concerning this project please do not hesitate to contact me at 828-698-9800.
Sincerely,
ylie A. Yar k
Project Manager
ATTACHMENTS
R. Clement Riddle, P.W.S
Principal
Attachment A — USFWS, Asheville Field Othce Letter, July 3,2018
Attachment B — Skybax Ecological Services, LLC, Bat Habitat Report
Attachment C — Threatened & Endangered Species & Habitat Assessment Report (Updated July
13, 2018)
Copy Furnished:
US Fish & Wildlife Service, Asheville Regional Office — Byron Hamstead

Attachment A
USFWS, Asheville Field Office Letter
July 3, 2018

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa Street
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
continents 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).
Proiect 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.

Federallv Protected Species
Service records indicate a mist net capture of the federally threatened northern long-eared bat
(Myotis septentrionahs) 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 (Myosis 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.

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 Clearin
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 Irrigation
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

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 Develo meat
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.

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; CIearWater Environmental Consultants, Inc.

Attachment B
Skybax Ecological Services, LLC
Winter Habitat Survey for Gray, Indiana, and Northern Long-eared Bat at
the High Hampton Redevelopment Project in Jackson County, North
Carolina
August 2018

Winter Habitat Survey for
Gray, Indiana, and Northern Long-eared Bat
at the High Hampton Redevelopment Project
in Jackson County, North Carolina
AUGUST 2o3.8
Skybax Ecological Services, LLC, PO Box io93, Berea, KY 40403.859302-2897

I. INTRODUCTION
Skybax Ecological Services, LLC, was contracted by Daniel Communities, Vestavia Hills,
AL, to conduct a thorough survey of rock outcrops at the High Hampton
Redevelopment Project, near Cashiers located in Jackson County, North Carolina. The
emphasis was on locating caves that might be used during the winter by Gray Bat
(Myotisgrisescens), Indiana bat (Myodssodalis), and/or Northern Long-eared bat
(Myotis septentrionalis).
This includes the boulder/rubble fields below the cliffs. These rock outcrops are highly
visible in the study area and composed of biotite gneiss. This type of geology can
contain caves (NCCS 1970 -1993), typically small, talus (or boulder) caves have been
previously documented in similar rock outcrops.
The following discussion of cave animals is from Barr (1961). Cave animals may be
divided into three groups, depending on their degree of specialization to subterranean
life. Animals that are so specialized that they are unable to live elsewhere are called
troglobites. Examples are the white, eyeless fishes and crayfishes. Animals that readily
spend their entire life underground but are also able to live in cool, moist situations on
the surface, often under logs or stones, are called troglophiles. Many of the beetles and
flies found on animal dung in caves are troglophiles. If an animal does not spend its
entire life cycle in the caves, but must return to the surface for some reason (usually
food), it is called a trogloxene. Trogloxenes can be subdivided into "habitual" (i.e.,
found frequently in caves) and `occasional" groups. Examples of trogloxenes are bats,
cave rats, and cave crickets. Special emphasis was placed on searching for suitable
habitat for cave -roosting bats.
11. STUDY AREA
The study area is the High Hampton Redevelopment Project, Jackson County, North
Carolina (project location map attached). This includes the boulder/rubble fields below
the cliffs as outlined on the map provided. No caves have been described within the
study area.
III. METHODS
The study area was thoroughly evaluated for the presence of suitable overwintering
habitat for these species (i.e., rock outcrops and subterranean caves). Prior to the field
surveys, the cave records for Jackson County, North Carolina, were checked to see if
there were any known caves within or near the study area. Three (3) experienced
savers surveyed the area for caves by walking back and forth and up and down
Skybax Ecological Services, LLC, PO Box 1o93, Berea, KY 40403.859-302-2897

throughout the rock outcrops searching for openings. When openings were found, they
were explored to the extent possible.
IV. RESULTS
No caves have been previously documented from within or nearthe study area. Field
surveys were conducted July 23 — 25, 2o28 by three experienced and trained cavers/bat
biologists (Gary Libby, Scott McCrea, and Buford Pruitt). These researchers have over
ioo years of combined experience. A few small boulder pile crawl -ins/crawl-throughs
and rock shelters were found in the study area (see photographs).
V. CONCLUSION
A few small boulder crawl- ins/crawl-throughs and rock shelters were found in the study
area (see photographs). These features were explored to the extent possible. These
features and rock shelters are small and have very limited underground (subterranean)
passages. Zones of complete darkness are lacking. No evidence of roosting bats was
observed (i.e., guano, staining on the rocks from bat guano and urine). The sloughing
of the large outcrops and basal erosion and weathering has not been extensive enough
to result in cave formation in this area. No caves or rock shelters were identified in the
study area that would provide overwintering habitat for gray, Indiana, and/or northern
long-eared bat.
VI. CITATIONS
Barr, T.C. 2962. Caves of Tennessee. State of Tennessee, Department of Conservation
and Commerce, Division of Geology, Bulletin 64. 567 pages.
North Carolina Cave Survey (NCCS), :1970 —2993. Volume 2 — 6 + A Special Report of
the North Carolina Cave Survey: A Compilation of Reported Caves, Yet
Undocumented.:': 47 pages, 2: 73 pages, 3: 26 pages, 4: 28 pages, 5: 23 pages, 6: 22
pages, and Special Report: 20 pages.
Skybax Ecological Services, LLC, PO Box io93, Berea, Ky 40403 . 859-302-2897

MAPS
Skybax Ecological Services, LLC, PO Boxio93, Berea, KY 40403.859 3oz-z897

Skybax Ecological Services, LLC, PO Box io93, Berea, KY 40403.859 3O2-2897

High Hampton (+/- 674 ACS
.aim
The bold red lines indicate the area of potential boulder/rubble fields below the cliffs.
Skybax Ecological Services, LLC, PO Box so33, Berea, KY 40403 0 859302-2897

PHOTOGRAPHS
Skybax Ecological Services, LLC, PO Box so93, Berea, KY 40403.859 3O2-.2897

s
Y
40
One of several small "crawl -ins" explored during field surveys.
Skybax Ecological Services, LLC, PO Box so93, Berea, KY 40403 0 859-302-2897

A rock shelter documented during field surveys. (35.107811-83.07264, So' wide x 24'
deep x 1o'high).
Skybax Ecological Services, LLC, PO Box so93, Berea, KY 40403 . 859-302-2897

Attachment C
Threatened and Endangered Species & Habitat Assessment
Updated July 13, 2018

High Hampton
Threatened and Endangered Species Survey
and Habitat Assessment
Approximately 690 acres
Jackson County, North Carolina
Prepared For
Daniel Communities
3104 Blue Lake Drive, Suite 200
Vestavia, AL 35243
Prepared By
C1earWater Environmental Consultants, Inc.
32 Clayton Street
Asheville, NC 28801
May 15, 2018
Updated July 13, 2018

Table of Contents
1.0
INTRODUCTION.................................................................................................... 3
2.0
METHODOLOGY...................................................................................................
3
3.0
HABITAT CLASSIFICATION................................................................................
4
3.1
Acidic Cove Forest...............................................................................................
4
3.2
Mountain Bog........................................................................................................
5
3.3
Headwater Forest Wetland.................................................................................... 5
3.4
Streams.................................................................................................................. 5
3.5
Mixed Hardwood — Pine Forest............................................................................ 6
3.6
Pine - Oak Heath.................................................................................................... 6
3.7
Open Water............................................................................................................
6
3.8
Turf / Landscaping / Maintained Areas.................................................................
6
3.9
Riparian Buffer......................................................................................................
7
4.0
SOILS.......................................................................................................................
7
5.0
PROTECTED SPECIES...........................................................................................
8
5.1
Bog turtle...............................................................................................................
8
5.2
Carolina northern flying squirrel...........................................................................
8
5.3
Gray Bat.................................................................................................................
9
5.4
Indiana Bat...........................................................................................................
10
5.5
Northern Iong-eared bat.......................................................................................
10
5.6
Appalachian elktoe..............................................................................................
11
5.7
Rusty -patched bumble bee...................................................................................
11
5.8
Spruce -Fir Moss Spider.......................................................................................
12
5.9
Small whorled pogonia........................................................................................
12
5.10 Swamp pink.........................................................................................................
12
5.11
Rock Gnome Lichen............................................................................................
13
6.0
FINDINGS..............................................................................................................
13
7.0
CONCLUSION AND RECOMMENDATIONS...................................................
14
8.0
REFERENCES.......................................................................................................
15
List of Tables
Table 1: US Fish and Wildlife Service List of Potential Threatened or Endangered
Species in
Jackson County, North Carolina
List of Figures
Figure 1: Site Vicinity Map
Figure 2: USGS Topographic Map
Figure 3: NCCGIA Aerial Photograph
Figure 4: USDA Soils Map
Appendices
Appendix A:
US Fish and Wildlife Service County Database Information
NC Natural Heritage Program Data
Northern Long -Eared Bat Consultation Areas Map
2

1.0 INTRODUCTION
The following report details the habitat assessment and results of the survey for the potential
occurrence of threatened and endangered (T&E) species for the High Hampton project site.
The referenced site is located south of U.S. Highway 64 and N.C. Route 107, adjacent to
either side of route 107 in Jackson County, North Carolina The site ranges in elevation from
approximately 3480 - 4280 feet above mean sea level (Figures 1-3).
A survey was conducted at the project site to determine the occurrence of or the potential for
animal and plant species listed as federally threatened and/or endangered to exist on the
proposed site. Completion of this survey was directed by and complies with current state
and federal regulations [Federal Endangered Species Act of 1973 (16 USC 1531-1543) and
the North Carolina Endangered Species Act (N.C.G.S. Sect. 113 article 25) and North
Carolina Plant Protection and Conservation Act of 1979 (N.C.G.S. Sect. 19b 106: 202.12-
22)].
2.0 METHODOLOGY
A habitat survey and protected species survey were conducted on August -September 2017,
May 3-4, 2018 and on July 13, 2018 at the referenced project site by Clearwater
Environmental Consultants, Inc. (CEC) to determine the potential for occurrences of animal
and plant species listed as endangered or threatened by current Federal regulations.
A recent literature review of the U.S. Fish and Wildlife Service (FWS) on May 10, 2018
provided existing data concerning the presence or potential occurrence of threatened or
endangered species in Jackson County, North Carolina (Appendix A). CEC also conducted
a file review of records maintained by the North Carolina Natural Heritage Program
(NHP) on January 16, 2018. The desktop literature review involved a review of the NHP
Element Occurrence Data on which NHP identifies current and historic occurrences of
listed species for a specific locale. The NHP database identifies 35 element occurrences
(EO) within a 1 -mile radius of the project site; 1 EO species holds a Federal status and is
subject to Section 7 consultation (Appendix A). The NHP database also identifies 7 EOs
within the project area, none of which are subject to Section 7 consultation. The Federally
listed species identified by the FWS and NHP are listed below:
Table 1.
Common Name
Scientific Name
Status
Bog turtle
Glyptemys muhlenbergii
Threatened (SIA)
Carolina northern flying squirrel
Glaucom s sabnnus coloratus
Endangered
Gray bat
M otis grisescens
Endangered
Indiana bat
M otis sodalis
Endangered
Northern long-eared bat
M ods se tentrionalis
Threatened
A alachian elktoe
Alasmidonta raveneliana
Endangered
Rusty -patched bumble bee
Bombus a rnis
Endangered
Spruce -fir moss spider
Microhemra montiva a
Endangered
Small whorled pogonia
Isotria medeoloides
Threatened EA

I Swamp pink I Helonias bullata I Threatened I
Rock gnome lichen I Gymnaderma lineare Endangered
*T(S/A) = threatened due to similarity of appearance. A taxon that is threatened due to similarity of appearance with another listed species
and is listed for its protection. Tana listed as T(SIA) are not biologically endangered or threatened and are not subject to Section 7
consuludic .
CEC consulted the FWS's "Northern Long -Eared Bat Consultation Areas" map for Jackson
County. The proposed project site is not in a Hydrologic Unit Code (HUC) identified as
having known occurrences of hibernation or maternity sites; therefore, the proposed project
is exempt from the tree cutting moratorium.
An office review of topographic maps and aerial photography, as well as, a pedestrian
survey of the site concurrent with the wetland delineation (August -September 2017) and
again on May 3-4, 2018 and July 13, 2018, indicated potential habitat for several of the
listed species; however, no species were observed. The pedestrian survey was conducted
by CEC staff and Ms. Julie Smoak, a certified botanist. During the field survey, CEC staff
walked transects throughout all the habitats observed. Site habitats were identified and
compared with recognized habitats for each of the species as potential flora and fauna were
identified to the taxonomic unit level necessary to determine if the observed specimen was a
protected species.
Approximately fifty occurrences of the Southern Appalachian purple pitcherplant were
documented by CEC during the May 2018 threatened and endangered species survey.
This vascular plant is listed as a Federal species of concern (FSC) and has been
previously documented on-site by the Highlands -Cashiers Land Trust. The plant
population is located within a wetland on the western edge of Hampton Lake, near
proposed fairway eighteen. Attention to grading and golf course planning would
eliminate potential threats from construction and site development. Specifically, impacts
to this area would be avoided, and the wetland would be preserved via a conservation
easement with Highlands -Cashiers Land Trust.
3.0 HABITAT CLASSIFICATION
During our visits to the project site, we observed nine distinct habitat types: acidic cove
forest, mountain bog, headwater forest wetland, stream, mixed hardwood -pine forest, pine -
oak heath, open water, turf/landscaping/maintained areas, and riparian buffer. The
following is a description of each of the nine habitat types identified on the referenced site
and its likelihood to harbor or support the listed species. Potential flora and fauna were
identified to the taxonomic unit level necessary to determine if the observed specimen was a
protected species. Plants were identified to the lowest taxonomic level readily discernible in
the field during the time of survey. The following is a list of habitats for the High Hampton
project site with a description of each of the habitat types. A soils discussion is also
provided.
3.1 Acidic Cove Forest
This habitat occurs in narrow, steep slopes. It has a dense forest canopy and a
dense shrub layer. The herb layer is sparse. Species observed include tulip poplar
4

(Liriodendron tulipifera), black birch (Betula lenta), eastern hemlock (Tsuga
canadensis), red maple (Acer rubrum), northern red oak (Quercus rubra), Eastern
white pine (Pinus strobus), pepperbush (Clethera alnifolia), Fraser magnolia
(Magnolia fraseri), great rhododendron (Rhododendron maximum), galax (Galax
aphylla), heartleaf (Hexastylis spp.), and autumn clematis (Clematis virginiana).
3.2 Mountain Bog
This habitat is primarily comprised of an herbaceous layer with some shrubs and is
lacking a canopy. These wetlands appeared to be semi permanently saturated. Shrub
and sapling species observed within these wetlands include pussy willow (Salix
discolor), great rhododendron, possumhaw viburnum (Viburnum nudum),
pinxterbloom azalea (Rhododendron periclymenoides), steeplebush (Spiraea
tomentosa), elderberry (Sambucus canadensis), swamp rose (Rosa palustris),
Japanese barberry (Berberis thunbergh), witch hazel (Hamamelis virginiana), and
chokeberry (Aronia arbutifolia). The herbaceous species observed include
sphagnum mosses (Sphagnum spp.), Joe Pye weed (Eutrochium fastulosum),
jewelweed (Impatiens capensis), sedge sp. (Carex spp.), woolgrass (Scirpus
cyperinus), Japanese siltgrass (Microstegium vimineum), green bullrush (Juncus
efjtusus), mountain bluets (Houstonia caerulea), buttercup (Rununculus spp.),
water hemlock (Cicuta maculata), raspberry (Rubus sp.), sensitive fern (Onoclea
sensibilis), wild strawberry (Fragaria virginia), bushy bluestem (Andropogon
glomeratus), golden ragwort (Packera aurea), pond -lily (Nuphar sp.), yellow
dock (Rumex crispus), rosette grass (Dicanthelium sp.), cottongrass (Eriophorum
virginicum.), and yellowroot (Xanthorhiza simplicissima). Also, a community of
the at -risk species, Southern Appalachian purple pitcherplant (Sarracenia purpurea),
was observed in the bog adjacent and connected to Hampton Lake.
3.3 Headwater Forest Wetland
Multiple headwater forest wetlands were observed within the project site. The main
factor contributing to hydrology in these wetlands were adjacent streams and
groundwater seeps. Species observed within these wetlands include pepperbush,
red maple, great rhododendron, sphagnum moss, New York fern (Thelypteris
noveboracensis), common blue violet (Viola sororia), Joe Pye weed, autumn
clematis, jewelweed, possumhaw viburnum, mountain bluets, and raspberry.
3.4 Streams
The High Hampton site contains several streams, generally flowing north to south,
located centrally on the property. There is one named perennial stream on-site:
Fowler Creek. This tributary generally flows north to south and transects the central
portion of the property. Additional unnamed tributaries to Fowler Creek were
identified on-site. Unnamed tributaries identified within the far northeastern section
of the project boundary drain off-site to Rochester Creek and the Horsepasture
River.

3.5 Mixed Hardwood — Pine Forest
This habitat has a closed canopy of pine and mixed hardwood trees. Overstory
species observed within this forest include scarlet oak (Quercus coccinea), white
pine, shortleaf pine (Pinus echinata), red maple, tulip poplar, black cherry
(Prunus serotina), cucumber magnolia (Magnolia acuminata), chinkapin oak
(Quercus muehlenbergii), shagbark hickory (Carya ovata), and black oak
(Quercus velutina). Shrub and sapling species include bear huckleberry
(Gaylussacia ursina), high bush blueberry (Vaccinium corymbosum), sparkleberry
(Vaccinium arboreum), mountain laurel (Kalmia latafolia), great rhododendron,
white ash (Fraxinus americana), viburnum (Viburnum sp.), American holly (Ilex
opaca), buffalo nut (Pyrularia pubera), alternate -leaved dogwood (Cornus
alternifolia), sugar maple (Acer saccharum), service berry (Amelanchier
arbores), and sweet shrub (Calycanthus floridus). The herbaceous species
observed include Catesby's trillium (Trillium catesbaei), painted trillium
(Trillium undulatum), dew berry (Rubus sp.), raspberry, wild strawberry, bellwort
(Uvularia sessilifolia), rattlesnake plantain (Goodyera pubescens), English ivy
(Hedera helix), firmoss (Huperzia sp.), pink lady slipper (Cypripedium acaule),
Solomon's seal (Poligonatum biflorum), meadow parsnip (Zizia trifoliate),
clubmoss (Lycopodium clavatum), running cedar (Lycopodium digitatum),
cranefly orchid (Tipularia discolor), Christmas fern (Polystichum acrostichoides),
rattlesnake root (Prenanthes altissima), fairy -wand (Chamaelirium luteum),
sedge, rosette grass, bowman's root (Gaillenia trifoliata), wild violet (Viola spp.),
halberd -leaved violet (Viola hastata), sassafras (Sassafras albidum), green and
gold (Chrysogonum virginianum), and goldenrod (Solidago sp.).
3.6 Pine - Oak Heath
This habitat is a mixed woodland with exposed montane areas and sharp ridges
and dry slopes. It is naturally dominated by pines and has a dense shrub layer.
Species observed include white pine, northern red oak, sourwood (Oxydendrum
arboreum), Fraser maganolia, Solomon's seal, alternate -leaved dogwood, bloodroot
(Sanguinaria canadensis), trillium (Trillium spp.), violet, hickory (Carya spp.),
witch hazel, fairy -wand (Chamaelirium luteum), sedge, red maple, scarlet oak, tulip
poplar, compass plant (Sylphium sp.), pink lady slipper, great rhododendron, black
oak, cleavers (Gallium aparine), bellwort, mountain mint (Pycnanthemum sp.).
3.7 Open Water
Approximately 16.45 acres of open water were delineated within the project
boundary. There are two lakes, Hampton Lake and Jewel Lake. The northeast end
of the open water connects to wetland habitat. Fowler creek flows out of the south
end of Jewel lake.
3.8 Turf / Landscaping / Maintained Areas

This habitat was observed in intervals throughout the project area including
mowed paths, powerline corridors, a recreational golf course, landscaped parking
lot, and commercial/residential lawns. Species that were observed within this
habitat include fescue (Festuca sp.), crabgrass (Digitaria sp.), common plantain
(Plantago major), white clover (Trifolium repens), common dandelion
(Taraxacum offacinale), black locust (Robinia pseudoacacia), heartleaf, raspberry,
pink lady slippers, bluegrass (Poa sp.), creeping bentgrass (Agrostis palustris),
English ivy, American box wood (Buxus sempervirens), river birch (Betula
nigra), eastern arborvitae (Thuja occidentalis), hosta (Hosta spp.), Fraser -fir
(Abies fraseri), Japanese maple (Acer palmatum), white pine, bald cypress
(Taxodium distichum), goldenrod, yarrow (Achillea millefolium), ragweed
(Ambrosia artemesiifolia), mullein (Verbascum thapsus), Norway spruce (Abies
pinagene), sacred bamboo (Nandina domestica), and flowering dogwood (Cornus
jlorida).
3.9 Riparian Buffer
Overstory species observed include tulip poplar, shagbark hickory, white pine,
Fraser magnolia, red maple, red oak, eastern hemlock, sourwood, black birch, and
yellow birch (Betula alleghensis). Shrub and sapling species observed include
pinxterbloom azalea, service berry, American holly, buffalo nut, great
rhododendron, witch hazel, pepperbush, alternate -leaved dogwood, and striped
maple (Acer pensylvanicum). Herbaceous species observed include devil's
walking stick (Aralia spinosa), rattlesnake plantain, trillium, yellowroot, Joe Pye
weed, mountain mint, buttercup, annual bluegrass (Poa annua), mountain bluets,
raspberry, wild lettuce (Lactuca spp.), pink lady slipper, meadow parsnip, mouse -
ear hawkweed (Hieradum pilosella), dog hobble, sphagnum moss, cucumber root
(Medeola virginiana), bellwort, New York fern, Cateby's trillium, painted
trillium, compass plant, striped wintergreen (Chimaphila maculata, and partridge
berry (Mitchella repens).
4.0 SOILS
The High Hampton project site is located within the Mountain Physiographic
Province of North Carolina. The soil series present include the following: Chestnut-
Edneyville complex, windswept, 8 to 15 percent slopes, stony (CnC); Chestnut-
Edneyville complex, windswept, 15 to 30 percent slopes, stony (CnD); Cleveland -
Chestnut -Rock outcrop complex, windswept, 50 to 95 percent slopes (CpF);
Cullasaja very cobbly fine sandy loam, 30 to 50 percent slopes, extremely bouldery
(CsE); Cullasaja-Tuckasegee complex„ 8 to 15 percent slopes, stony (CuC);
Cullasaja-Tuckasegee complex, 15 to 30 percent slopes, stony (CuD); Cullasaja
Tuckasegee complex, 30 to 50 percent slopes, stony (CuE); Edneyville-Chestnut
complex, 8 to 15 percent slopes, stony (EdC); Edneyville-Chestnut complex, high
precipitation, 15 to 30 percent slopes, stony (EdD); Edneyville-Chestnut complex,
high precipitation, 30 to 50 percent slopes, stony (EdE); Nikwasi fine sandy loam, 0
to 2 percent slopes, frequently flooded (NkA); Rock outcrop -Cleveland complex,
windswept, 30 to 95 percent slopes (RkF); Sylva-Whiteside complex, 0 to 2 percent

slopes (SyA); Tuckasegee-Whiteside complex, 8 to 15 percent slopes (TwC);
Udorthents, loamy (Ud); Udorthents-Urban land complex, 0 to 5 percent slopes,
rarely flooded (UfB); and Whiteside-Tuckasegee complex, 2 to 8 percent slopes
(WtB) (Figure 4).
5.0 PROTECTED SPECIES
The following is a brief description of the federally listed species included in the survey, its
recognized habitat and comments regarding survey results for that species:
5.1 Bog turtle
The Bog turtle (Glyptemys muhlenbergia), is federally listed as threatened in North
Carolina. This is the smallest emydid turtle, and one of the smallest turtles in the
world, rarely exceeding three or four inches in length and weighing only about four
ounces. Its orange to yellow patch on either side of the neck easily distinguishes it
from other turtles
Bog turtles live in the mud, grass and sphagnum moss of bogs, swamps and marshy
meadows. These wetlands are usually fed by cool springs flowing slowly over the
land, creating the wet, muddy soil needed by these turtles.
The southern population of the bog turtle, ranging from southern Virginia to northern
Georgia, is also protected with a threatened designation because its physical
appearance is similar to the northern population. The southern bog turtle population is
separated from the northern population by approximately 250 miles. However,
individual bog turtles in the southern population closely resemble individuals in the
northern bog turtle population, causing difficulty in enforcing prohibitions protecting
the northern population. Therefore, the Service is designating the southern population
as "threatened (similarity of appearance)." This designation prohibits collecting
individual turtles from this population and bans interstate and international commercial
trade. It has no effect on land management activities of private landowners in southern
states where the bog turtle lives.
Suitable habitat for the southern bog turtle was found on the project site, but no
evidence of this turtle was observed. It is the opinion of CEC that the proposed project
is not likely to adversely affect the northern bog turtle.
5.2 Carolina northern flying squirrel
The Carolina Northern flying squirrel (Glaucomys sabrinus coloratus), is one of two
species of flying squirrels in the Southern Appalachians — the northern (Glaucomys
sab)dnus coloratus) and southern (Glaucomys volans). Northern flying squirrels are
about one-third larger than the very common southern species. Also, northern flying
squirrels are brown on their backs, and their fur fades to a buff white on the belly.
Southern flying squirrels are grayer on their backs with bright white bellies, and a

clearly defined (usually black) line separates the fur colors. The endangered Carolina
northern flying squirrel is a subspecies of the northern flying squirrel.
Flying squirrels are nocturnal and have large eyes to help them see at night. They
cannot actually fly, but glide by extending a fold of skin that stretches from their
wrists to their ankles. The flattened tail acts as a rudder. Carolina northern flying
squirrels are relicts of the last ice age. As the glaciers retreated northward and
temperatures rose, remnant populations remained in the suitable habitat left behind
on the high mountain tops along the ridges of the Southern Appalachian Mountains.
Northern flying squirrels principally feed on certain fungi and lichens, though they
do occasionally eat some fruits and nuts. They're active year-round, but more so in
the warmer summer months. They nest in tree cavities in nests made almost
exclusively of yellow birch bark, where two to six young are born in early spring.
Groups of squirrels often occupy the same tree cavity, particularly in the colder
winter months. Northern flying squirrels are typically found in areas where northern
hardwoods, such as yellow birch, are adjacent to the higher -elevation red spruce -
Fraser fir forest. These habitats are often moist and cool.
Suitable habitat for northern flying squirrel does not exist within the project site. It
is the opinion of CEC that the proposed project is not likely to adversely affect the
northern flying squirrel.
5.3 Gray Bat
The gray bat (Myotic grisescens) is the largest member of its genus in the eastern
United States. Its forearm measures 40-46 mm, and it weighs from 7-16 grams. It is
easily distinguished from all other bats within its range by its mono -colored fur. All
other eastern bats have distinctly bi-or tri -colored fur on their backs. Following molt
in July or August, gray bats are dark gray, but they often bleach to chestnut brown or
russet between molts (especially apparent in reproductive females during May and
June). The wing membrane connects to the foot at the ankle rather than at the base of
the first toe, as in other species of Myotis. Gray bats roost in caves year-round. Most
winter caves are deep and vertical; all provide large volume below the lowest
entrance and act as cold air traps. A much wider variety of cave types are used
during spring and fall transient periods. In summer, maternity colonies prefer caves
that act as warm air traps or that provide restricted rooms or domed ceilings that are
capable of trapping the combined body heat from thousands of clustered individuals.
No naturally occurring suitable winter habitat (caves) for the gray bat was observed
on this site. It is the opinion of CEC that the project is not likely to adversely affect
the gray bat.

5.4 Indiana Bat
The Indiana bat (Myons sodahs) is federally listed as an endangered species. It is a
medium-sized Myotis closely resembling the little brown bat (Myotis lucifugus) but
differing in coloration. Its fur is a dull grayish chestnut rather than bronze, with the
basal portion of the hairs of the back dull lead colored. This bat's underparts are
pinkish to cinnamon, and its hind feet smaller and more delicate than in M. lucifugus.
The calcar is strongly keeled. This species uses limestone caves for winter
hibernation. The preferred caves have a temperature averaging 37 degrees to 43
degrees Fahrenheit in midwinter, and a relative humidity averaging 87 percent.
Summer records are rather scarce. A few individuals have been found under bridges
and in old buildings, and several maternity colonies have been found under loose
bark and in the hollows of trees. Summer foraging by females and juveniles is
limited to riparian and floodplain areas. Creeks are apparently not used if riparian
trees have been removed. Males forage over floodplain ridges and hillside forests
and usually roost in caves. Foraging areas average 11.2 acres per animal in
midsummer. This bat has a definite breeding period that usually occurs during the
first 10 days of October. Mating takes place at night on the ceilings of large rooms
near cave entrances. Limited mating may also occur in the spring before the
hibernating colonies disperse.
No naturally occurring suitable wintering habitat (large ceilinged caves) for the
Indiana bat was observed on this site. It is the opinion of CEC that the proposed
project is not likely to adversely affect the Indiana bat.
5.5 Northern long-eared bat
The Northern long-eared bat (Myotis septentrionalis), is a medium-sized bat about 3
to 3.7 inches in length but with a wingspan of 9 to 10 inches. As its name suggests,
this bat is distinguished by its long ears, particularly as compared to other bats in its
genus, Myotis, which are actually bats noted for their small ears (Myotis means
mouse -eared). The northern long-eared bat is found across much of the eastern and
north central United States and all Canadian provinces from the Atlantic coast west
to the southern Northwest Territories and eastern British Columbia. Northern long-
eared bats spend winter hibernating in caves and mines, called hibernacula. They
typically use large caves or mines with large passages and entrances; constant
temperatures; and high humidity with no air currents. No naturally occurring
suitable wintering habitat for the northern long-eared bat exists within the property
boundary. Summer habitat for the Northern long-eared bat consists of the cavities,
hollows, cracks, or loose bark of live or dead trees typically greater than three inches
DBH (diameter at breast height). Suitable summer habitat for the Northern long-
eared bat was observed within the proposed site.
CEC consulted the FWS's "Northern Long -Eared Bat Consultation Areas" map for
Jackson County (see attached appendix A). The proposed project site is not in a
Hydrologic Unit Code (HUC) identified as having known occurrences of hibernation
10

or maternity sites. It is the opinion of CEC that any incidental take associated with
proposed activities would be exempt under the 4(d) rule.
5.6 Appalachian elktoe
Appalachian elktoe (Alismidonta raveniliana), is federally listed as endangered. This
freshwater mussel has a thin but not fragile, kidney -shape shell, reaching up to about
3.2 inches in length, 1.4 inches in height, and 1.0 -inch -wide (Clarke 1981).
Juveniles generally have a yellowish -brown periostracum (outer shell surface) while
the periostracum of the adults is usually dark brown to greenish -black in color.
Although rays are prominent on some shells, particularly in the posterior portion of
the shell, many individuals have only obscure greenish rays. The shell nacre (inside
shell surface) is shiny, often white to bluish -white, changing to a salmon, pinkish, or
brownish color in the central and beak cavity portions of the shell; some specimens
may be marked with irregular brownish blotches (adapted from Clarke 1981). Only
two populations of the species are known to survive. The healthiest of these
populations exists in the main stem of the Little Tennessee River between Emory
Lake at Franklin, Macon County, North Carolina, and Fontana Reservoir in Swain
County, North Carolina. The second population occurs in the Nolichucky River
system. The Appalachian elktoe has been reported from relatively shallow, medium-
sized creeks and rivers with cool, well -oxygenated, moderate- to fast -flowing water.
It has been observed in gravelly substrates often mixed with cobble and boulders, in
cracks in bedrock, and occasionally in relatively silt -free, coarse, sandy substrates
(Department of the Interior 1994).
Suitable habitat for Appalachian elktoe does not exist within proposed project sites.
The stream substrate is dominated by silt, gravel and fine sand. It is the opinion of
CEC that the project is not likely to adversely affect the Appalachian elktoe.
5.7 Rusty -patched bumble bee
Rusty -patched bumble bee (Bombus ajjinis), is listed under Historic Record Status in
Henderson County. Rusty patched bumble bees once occupied grasslands and
tallgrass prairies of the Upper Midwest and Northeast, but most grasslands and
prairies have been lost, degraded, or fragmented by conversion to other uses. Bumble
bees need areas that provide nectar and pollen from flowers, nesting sites
(underground and abandoned rodent cavities or clumps of grasses), and
overwintering sites for hibernating queens (undisturbed soil). Rusty patched bumble
bees live in colonies that include a single queen and female workers. The colony
produces males and new queens in late summer. Queens are the largest bees in the
colony, and workers are the smallest. All rusty patched bumble bees have entirely
black heads, but only workers and males have a rusty reddish patch centrally located
on the back. Bumble bees gather pollen and nectar from a variety of flowering
plants. The rusty patched emerges early in spring and is one of the last species to go
into hibernation. It needs a constant supply and diversity of flowers blooming
throughout the colony's long life, April through September.
11

Suitable habitat for rusty patched bumble bee does not exist within the project site
nor was it observed during the survey. It is the opinion of CEC that the proposed
project is not likely to adversely affect the rusty patched bumble bee.
5.8 Spruce -Fir Moss Spider
The spruce -fir moss spider (Microhexura nomtivaga) is federally listed as an
endangered species. It is one of the smallest members of the primitive suborder of
spiders popularly referred to as "tarantulas." Adults of this species measure only
0.10 to 0.15 inch (2.5 -- 3.8 millimeters) (about the size of a BB). Coloration of the
spruce -fir moss spider ranges from light brown to yellow-brown to a darker reddish
brown, and there are no markings on its abdomen.
The spruce -fir moss spider only lives on the highest mountain peaks in the Southern
Appalachian Mountains of western North Carolina and eastern Tennessee. The high
elevation forests where this spider is found are dominated by Fraser fir with scattered
red spruce. This forest type is commonly referred to as spruce -fir forests. The
typical habitat of this spider is damp, but well -drained moss mats growing on rocks
and boulders in well -shaded areas within these forests. The moss mats cannot be too
dry (the species is very sensitive to desiccation) or too wet (large drops of water can
also pose a threat to the spider).
The spruce -fir moss spider is limited to a handful of mountains in western North
Carolina and eastern Tennessee. The site does not support higher elevation species
suitable for spruce -fir moss spider. It is the opinion of CEC that the proposed project
is not likely to adversely affect the spruce -fir moss spider.
5.9 Small whorled pogonia
Small whorled pogonia (Isotria medeoloides), is federally listed as a threatened
species. It is described as a herbaceous plant approximately 3.7-9.8 inches tall with a
smooth, hollow pale green stem. It produces a single whorl of five to six light green
elliptical leaves, 3 inches long and 1.6 inches wide. The flower or flowers
(occasionally two) are borne at the top of the stem. Habitat varies widely from white
pine stands, dry deciduous woods, rich cove hardwood forest mixed with hemlock.
All sites have a low shrub and sapling density.
Potentially, suitable habitat for this species was found within portions of the project
area. Although this plant was not observed at the proposed project site, it is the
opinion of CEC that the proposed project is not likely to adversely affect the small
whorled pogonia.
5.10 Swamp pink
Swamp pink (Helonias bullata), is federally listed as a threatened species and is
found in wetlands that are saturated but not flooded. This would include southern
Appalachian bogs and swamps. Swamp pink would also be found in Atlantic white
12

cedar swamps and swampy forests bordering small streams, boggy meadows and
spring seepage areas. This species is commonly associated with some evergreens,
including white cedar, pitch pine, American larch, and black spruce. It can be
distinguished by its basal rosette of light green, lance -shaped and parallel -veined
leaves with a hollow -stemmed flower stalk that can grow 8-35 inches during
flowering and up to 5 feet during seed maturation. Flowering occurs March through
May and flowers are clustered (30-50) at the tip of the stem, in a bottlebrush shape.
Potentially, suitable habitat for this species was found within portions of wetland
areas. Although this plant was not observed at the proposed project site, it is the
opinion of CEC that the proposed project is not likely to adversely affect swamp
pink.
5.11 Rock Gnome Lichen
Federally listed as an endangered species, rock gnome lichen (Gymnoderma lineare)
occurs on rocks in areas of high humidity either at high elevations (usually vertical
cliff faces) or on boulders and large rock outcrops in deep river gorges at lower
elevations. Distinguishing characteristics include dense colonies of narrow (.04
inch) straps that are blue -grey on the upper surface and generally shiny -white on the
lower surface. Near the base they grade to black (the similar species of Squamulose
cladonias are never blackened toward the base). Fruiting bodies are borne at the tips
of the straps and are black (similar Cladonia species have brown or red fruiting
bodies). Flowering occurs July through September.
Suitable habitat for this species was not observed in the project area. Rock outcrops
do not exist on the project site. However, rock gnome lichen is on High Hampton
property in an area that is protected by a conservation easement held by the
Highland -Cashiers Trust. This easement is outside of the project area. This project is
not likely to have any effect on the rock gnome lichen.
6.0 FINDINGS
During completion of the threatened and endangered species habitat assessments for the
project site, CEC observed potential suitable habitat for the bog turtle, small whorled
pogonia and swamp pink. A survey was conducted within these habitats to determine the
presence or absence of the threatened or endangered species. Potential flora and fauna
were identified to the taxonomic unit level necessary to determine if the observed
specimen was a protected species. No threatened or endangered species were observed
on the project site during the August -September 2017, May 3-4, 2018 and July 13, 2018
surveys.
Approximately fifty occurrences of the Southern Appalachian purple pitcherplant were
documented by CEC during the May 2018 threatened and endangered species survey.
This vascular plant is listed as a Federal species of concern (FSC) and has been
previously documented on-site by the Highlands -Cashiers Land Trust. The plant
population is located within a wetland on the western edge of Hampton Lake, near
13

proposed fairway eighteen. Attention to grading and golf course planning would
eliminate potential threats from construction and site development. Specifically, impacts
to this area would be avoided, and the wetland would be preserved via a conservation
easement with Highlands -Cashiers Land Trust.
After receiving requests for additional information from the US Fish and Wildlife Service
and the Wildlife Resources Commission during permit application review, a follow-up
survey was conducted on July 13, 2018, with particular emphasis on the High
Hampton/Chattooga Ridge Natural Area. One occurrence of Packera millefolium
(divided leaf ragwort) was documented approximately 10 feet outside of the project
boundary along the western edge of the High Hampton/Chimneytop Mountain
conservation easement. No other occurrences of Packera millefolium or other Federally
endangered species were observed.
7.0 CONCLUSION AND RECOMMENDATIONS
It is the opinion of C1earWater Environmental Consultants, Inc. that potentially, suitable
habitat for threatened or endangered species may be present within portions of the project
boundary. However, no threatened or endangered species were observed within the
project boundary during the survey. As such, development of this project is not likely to
adversely affect federally threatened or endangered species. Because of the transitory
nature of some of the listed threatened and endangered species and the particular
flower/fruiting periods of some plants, it is possible that endangered species populations
and locations may change over time. Therefore, any potential findings at a later date
should be fully investigated and coordinated with appropriate agencies to prevent
potential adverse impacts.
14

8.0 REFERENCES
Benyus, J.M. 1989. The field guide to wildlife habitats of the eastern United States.
Simon and Schuster Inc. New York, NY.
North Carolina Natural Heritage Program Online Data Search. Department of Natural and
Cultural Resources, Office of Land and Water Stewardship, Raleigh, NC;
accessed January 16, 2018.
Radford, A.E., H.E. Ashles and C.R. Bell. 1964. Manual of the vascular flora of
the Carolinas. The University of North Carolina Press. Chapel Hill, NC.
Schafale, M.P., and A.S. Weakley. 1990. Classification of the natural communities
of North Carolina: third approximation. North Carolina Natural Heritage
Program Division of Parks and Recreation. North Carolina Dept. of
Environment, Health, and Natural Resources; accessed January 18, 2018.
United States Fish and Wildlife Service Division of Endangered Species. Species
accounts at http://www.fws.gov/endangered/raleigh/species/cntylist.httnl;
accessed January 18, 2018.
15

High Hampton (+1- 690 AC)
Jackson County, Gear \! V"ber Site Vicinity
North Carolina -
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APPENDIX A
AGENCY CORRESPONDENCE
14

Jackson County Endangered Species, Threatened Species,Federal Species of Concern, and Candidate Species
U.S. Fish & Wildlife Servic�
Endangered Species, Threatened Species,Federal Species of Concern, and
Candidate Species,
Jackson County, North Carolina
Updated: 03-22-2018
Critical Habitat Designations:
Appalachian elktoe - Alasmidonta raveneliana - The main stem of the Tuckasegee River (Little Tennessee River
system), from the N.C. State Route 1002 Bridge in Cullowhee, Jackson County, North Carolina, downstream to the N.C.
Highway 19 Bridge, north of Bryson City, Swain County, North Carolina. Within these areas, the primary constituent
elements include: (i) Permanent, flowing, cool, clean water; (ii)Geomorphically stable stream channels and banks;
(iii)Pool, riffle, and run sequences within the channel; (iv)Stable sand, gravel, cobble, boulder, and bedrock substrates
with no more than low amounts of fine sediment; (v)Moderate to high stream gradient; (vi)Periodic natural flooding;
and (vii)Fish hosts, with adequate living, foraging, and spawning areas for them.
Federal Register Reference: September 27, 2002, Federal Register, 67:61016-61040.
Common Name
Vertebrate:
Appalachian Bewick's wren
Bog turtle
Carolina northern flying sQuirrel
Eastern small -footed bat
Gray bat
Green salamander
Hellbender
Indiana bat
Northern long-eared hat
Northern pine snake
Scientific name
Federal
Record Status
Status
Thryomanes bewickii altos
FSC
Historic
Glyptemys muhlenbergii
T (SIA)
Probable/potential
Glaucomys sabrinus coloratus
E
Current
Myosis leibd
ARS
Current
Myotis grisescens
E
Probably/Potential
Aneides aeneus
ARS
Current
Cryptobranchus alleganiensis
ARS
Current
Myosis sodalis
E
Current
Myotis septentrionalis
T
Current
Pituophis melanoleucus
FSC
Current
melanoleucus
https://www.fws.gov/raleigh/species/cntylist/jackson.html[5/10/2018 3:08:19 PM]

Jackson County Endangered Species, Threatened Species,Federal Species of Concern, and Candidate Species
Northern saw -whet owl (Southern
Aegolius acadicus pop. I
FSC
Current
Appalachian population)
Olive darter
Percina squamata
FSC
Current
Pygmy salamander
Desmognathus wrighti
FSC
Current
Red crossbill (Southern Appalachian) Loxia curvirostra
FSC
Current
Sicklefin redhorse
Moxostoma sp. 2
C
Current
Smoky dace
Clinostomus funduloides ssp.
FSC
Current
Southern Appalachian black -capped
Poecile atricapillus practices
FSC
Current
chickadee
Yellow -bellied sapsucker (Southern
Sphyrapicus varius appalachiensis
FSC
Current
Appalachian population)
wounded darter
Etheostoma vulneratum
FSC
Current
Invertebrate:
Anpalachiau elktoe
Alasmidonta ravenehana
E
Current
French Broad crayfish
Cambarus reburrus
FSC
Current
Rusty-patchedBombus
affinis
E
Historic
Southern Tawny Crescent butterfly
Phyciodes batesii maconensis
FSC
Current
Spruce -fir rossapider
Microhexura montivaga
E
Current
a harvestman
Fumontana deprehendor
FSC
Current
Vascular Plant:
Butternut
Juglans cinerea
FSC
Current
Balsam Mountain Gentian
Gentiana latidens
FSC
Current
Balsam Mountain Hawthorn
Crataegus oreophila
FSC
Current
Divided -leaf Ragwort
Packera millefolium
FSC
Current
Fraser fir
Abies fraseri
FSC
Current
Fraser's loosestrife
Lysimachia fraseri
FSC
Current
Gorge filmy fern
Hymenophyllum tayloriae
FSC
Current
Granite dome goldenrod
Solidago simulans
FSC
Current
Lobed Barren -strawberry
Geum lobatum
FSC
Historic
Mountain Thaspium
Thaspium pinnatifidum
FSC
Historic
Radford's sedge
Carex radfordii
FSC
Current
Small Whorled pogonia
Isotria medeoloides
T
Current
Southern Oconee -bells
Shortia galacifolia var. galacifolia
FSC
Historic
Swamp pink
Helomas bullata
T
Current
Southern appalachian purple
Sarracenia purpurea var. montana
ARS
Current
pitcherplant
Smoky Mountain Mannagrass
Glyceria nubigena
FSC
Current
Torrey's Mountain -mint
Pycnanthemum torrei
FSC
Historic
Nonvascular Plant:
a liverwort
Plagiochila cuduciloba
FSC
Current
a liverwort
Plagiochila sharpii
ARS
Current
a liverwort
Plagiochila sullivantii var. spinigera
FSC
Historic
a liverwort
Plagiochila sullivantii var. sullivantii
FSC
Historic
a liverwort
Plagiochila virginica var. caroliniana
FSC
Historic
a liverwort
Sphenolobopsis pearsonii
FSC
Current
https://www.f%vs.gov/raleigh/species/r,ntylist/jackson.html[5/10/2018 3:08:19 PM]

Jackson County Endangered Species, Threatened Species,Federal Species of Concent, and Candidate Species
Appalachian Pocket Moss Fissidens appalachensis ARS Current
Lichen:
Rock gnomelichen Gymnoderma lineare E Current
Definitions of Federal Status Codes:
E = endangered. A taxon "in danger of extinction throughout all or a significant portion of its range."
T = threatened. A taxon "likely to become endangered within the foreseeable future throughout all or a significant
portion of its range."
C = candidate. A taxon under consideration for official listing for which there is sufficient information to support listing.
(Formerly "C1" candidate species.)
BGPA =Bald and Golden Eagle Protection Act. See below.
ARS = At Risk Species
FSC=Federal Species of Concern. FSC is an informal term. It is not defined in the federal Endangered Species Act. In
North Carolina, the Asheville and Raleigh Field Offices of the US Fish and Wildlife Service (Service) define Federal
Species of Concern as those species that appear to be in decline or otherwise in need of conservation and are under
consideration for listing or for which there is insufficient information to support listing at this time. Subsumed under the
term "FSC" are all species petitioned by outside parties and other selected focal species identified in Service strategic
plans, State Wildlife Action Plans, or Natural Heritage Program Lists.
T(S/A) = threatened due to similarity of appearance. A taxon that is threatened due to similarity of appearance with
another listed species and is listed for its protection. Taxa listed as T(S/A) are not biologically endangered or threatened
and are not subject to Section 7 consultation. See below.
EXP = experimental population. A taxon listed as experimental (either essential or nonessential). Experimental,
nonessential populations of endangered species (e.g., red wolf) are treated as threatened specie_ s on public land, for
consultation purposes, and as species proposed for listing on private land.
P = proposed. Taxa proposed for official listing as endangered or threatened will be noted as "PE" or "PT", respectively.
In the July 9, 2007 Federal Register( 72:37346-37372), the bald eagle was declared recovered, and removed (de -listed)
from the Federal List of Threatened and Endangered wildlife. This delisting took effect August 8,2007. After delisting,
the Bald and Golden Eagle Protection Act (Eagle Act) (16 U.S.C. 668-668d) becomes the primary law protecting bald
eagles. The Eagle Act prohibits take of bald and golden eagles and provides a statutory definition of "take" that includes
"disturb". The USFWS has developed National Bald Eagle Management Guidelines to provide guidance to land
managers, landowners, and others as to how to avoid disturbing bald eagles. For mor information, visit
In the November 4, 1997 Federal Register (55822-55825), the northern population of the bog turtle (from New York
south to Maryland) was listed as T (threatened), and the southern population (from Virginia south to Georgia) was listed
as T(S/A) (threatened due to similarity of appearance). The T(S/A) designation bans the collection and interstate and
international commercial trade of bog turtles from the southern population. The T(S/A) designation has no effect on
land management activities by private landowners in North Carolina, part of the southern population of the species. In
addition to its official status as T(S/A), the U.S. Fish and Wildlife Service considers the southern population of the bog
turtle as a Federal species of concern due to habitat loss.
Definitio s of Record Status:
Current - the species has been observed in the county within the last 50 years.
Historic - the species was last observed in the county more than 50 years ago.
Obscure - the date and/or location of observation is uncertain.
Incidental/migrant - the species was observed outside of its normal range or habitat.
Probable/potential - the species is considered likely to occur in this county based on the proximity of known records (in
adiaaent counties), the presence of potentially suitable habit-., or both.
https://www,fws.gov/raleigh/species/cntylist/jackson.html[5/10/2018 3:08:19 PM]

Jackson County Endangered Species, Threatened Species,Federal Species of Concern, and Candidate Species
https://www.fws.gov/ndeigh/species/cntylist/jackson.html[5/10/20I8 3:08:19 PM]

4� �M111�
North Carolina Departrnent of Natural and Cultural Resources
Natural Heritage Program
envemor Roy Cooper
January 16, 2018
Britten Yant
ClearWater Environmental
9205 Davis Grey Drive
Asheville, NC 28803
RE: High Hampton; 918
Dear Britten Yant:
Secretary Susi H_ Hamilton
NCNHDE-5083
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide information
about natural heritage resources for the project referenced above.
A query of the NCNHP database indicates that there are records for rare species, important natural
communities, natural areas, or conservation/managed areas within the proposed project boundary. These
results are presented in the attached 'Documented Occurrences' tables and map.
The attached 'Potential Occurrences' table summarizes rare species and natural communities that have been
documented within a one -mile radius of the property boundary. The proximity of these records suggests that
these natural heritage elements may potentially be present in the project area if suitable habitat exists and is
included for reference. Tables of natural areas and conservation/managed area within a one -mile radius of the
project area, if any, are also included in this report.
Please note that natural heritage element data are maintained for the purposes of conservation planning, project
review, and scientific research, and are not intended for use as the primary criteria for regulatory decisions.
Information provided by the NCNHP database may not be published without prior written notification to the
NCNHP, and the NCNHP must be credited as an information source in these publications. Maps of NCNHP
data may not be redistributed without permission.
Also please note that the NC Natural Heritage Program may follow this letter with additional correspondence if a
Dedicated Nature Preserve (DNP), Registered Heritage Area (RHA), Clean Water Management Trust Fund
(CWMTF) easement, or an occurrence of a Federally -listed species is documented near the project area.
If you have questions regarding the information provided in this letter or need additional assistance, please
contact Rodney A. Butler at mdney.butler ncdcr.ggv or 919.707.8603.
Sincerely,
NC Natural Heritage Program
MAILING ADDRESS: Telephone: M19)707 -81U7
LOCATION_
1651 Mari Service Center www.ncnhp.org 121 West Jones Sbeet
Raleigh, NC 27659-1651 Rakdgh, NC 276D3

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Intersecting the Project Area
High Hampton
Project No. 918
January 16, 2018
NCNHDE-5053_
Elamant Occurrences Documented Within Project Area
_
p Observation Occurrence Status
Status
Rank Rank`.
Oahe
Freshwater Fish 32196 Notropis lutipinnis Yellowfin Shiner 2012-06-13 E 3-Medium --
Special
G40 S2
Natural 1242 High Elevation Granitic 2015-06-03 A 3-Medium --
Concern
--
G2G3 53
Community Dome
Natural 19646 Montane Oak—Hickory 2010 B9 3-Medium —
--
G4G5 S4S5
Community Forest (Acidic Subtype)
Vascular Plant 10448 Packera millefolium Divided-leaf Ragwort 2014-11-24 B 3-Medium Species of
Threatened
G3 S2
Concern
Vascular Plant 9214 Rhododendron vaseyi Pink-shell Azalea 2015-06-03 A 3-Medium --
Significantly
G3 S3
Vascular Plant 34538 Solidago simulans Granite Dame Goldenrod 2013-07-25 C 3-Medium Species of
Rare Limited
Significantly
G2 S2
Concern
Rare Limited
Natural Areas Documented Wtt _ _
_ _. Within Project Area
'r .�
..:
High Hampton/Chattooge Ridge Natural Area R3 (High) C3 (High)
Managed Areas Documented Within Project Area
Highlands-Cashiers Land Trust Easement Highlands-Cashiers Land Trust Private
NOTE: Hthe proposed project intersects with a conservatianlmanaged area, please contact the landowner directly for additional information. If the project intersects with a Dedicated Nature Preserve (DNP), Registered Natural
Heritage Area (RHA), or Federally-listed species, NON HP staff may provide additional correspondence regarding the
project.
Definitions and an explanation of status designations and codas can be found at Data quary generated on January 16, 2018; source:
NCNHP, 04 October 2017. Please
your information request if more than one year elapses before project Initiation as new Information Is continually added to the NCNHP database.
resubmit
Page 2 of 6

Page 3 of 6
Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One -mite Radius of the Project Area
High Hampton
Project No. 918
January 18, 2018
NCNHOE-5083
Element Occurrences Documented Within a_.One-mile Radius of the Project Area
_
P
Observation Occurrence
Status
Status
Rank
Rank.
D.ft,
1
Amphibian
34532
Aneides seneus
Green Salamander
2014-11-05
E
2 -High Species of
Endangered
G3G4
S283
Crustacean
33122
Cambarus chaugaensis
Chauga Crayfish
2012-06-13
Concern
3 Medium Species of
Special
G2
52
Crustacean
8714
Cambarus reburrus
French Broad River
2012-06-13
E
Concern
3 -Medium Species of
Concern
Significantly
G3
82
Crustacean
32831
Cambarus reburrus
Crayfish
French Broad River
2012-06-13
Concern
3 -Medium Species of
Rare
Significantly
G3
S2
Dragonfly or
33722
Somatochlora elongate
Crayfish
Ski -tipped Emerald
2004 -Pre
H?
Concern
5 -Very —
Rare
Significantly
G5
S2S3
Damselfly
Low
Rare
Dragonfly or
33764
Stylurus scudded
Zebra Clubtail
2004 -Pre
H?
5 -Very —
Significantly
G4G5
52?
Damselfly
Low
Rare
Freshwater Fish
13455
Notropis lutipinnis
Yellowfin Shiner
2012-06-13
E
3 -Medium —
Special
G4Q
S2
Freshwater Fish
32196
Notropis lutipinnis
Yellowfin Shiner
2012-06-13
E
3 -Medium
Concern
Special
G40
S2
Lichen
33912
Gymnoderma lineare
Rock Gnome Lichen
2015-06-03
A
3 -Medium Endangered
Concern
Endangered
G3
S3
Moss
34536
Macrocoma sullivantit
Sullivanfa Maned -moss
2013-09-11
E
2 -High ...
Significantly
G3G5
S2
Natural
9556
Canada Hemlock Forest
—
2010
A?
3 -Medium —
Rare Disjunct
—
G3G4
SiS2
Community
(Typic Subtype)
Natural
5244
Carolina Hemlock Forest
---
2012
C
3 -Medium
—
G2
S1S2
Community
(Pine Subtype)
Natural
13927
Heath Bald (Southern
2012
C
2 -High
—
Gi
S1
Community
Mixed Subtype)
Natural
4060
High Elevation Granitic
1992-04-20
B?
4 -Low
-
G2G3
S3
Community
Dome
Natural
1242
High Elevation Granitic
--
2015-06-03
A
3 -Medium --
G2G3
S3
Community
Dome
Natural
28294
High Elevation Granitic
...
2009-06-11
B
2 -High —
G2G3
S3
Community
Dome
Page 3 of 6

Element Occurrences Documented Within a One -mile Radius of the Project Area
I"
i. ,y
P
Observation
Occurrence
Status
Status
Rank
Ran1C:Ri
Date
Rank
Natural
13307
High Elevation Granitic
—
2010
C
2 -High
—
G2G3
83
Community
Dome
Natural
8212
Montane Oak—Hickory
--
1992-04-20
8
4 -Low
--
...
G4G5
S4S5
Community
Forest (Acidic Subtype)
Natural
19646
Montane Oak --Hickory
--
2010
B?
3 -Medium
--
G4G5
S4S5
Community
Forest (Acidic Subtype)
Natural
7106
Pine—Oak/Heath (Typic
--
2010
NR
4 -Low
--
G3
S3
Community
Subtype)
Natural
7019
Pine-Oak[Heath (Typic
-
2010
B?
3 -Medium
—
—
G3
S3
Community
Subtype)
Natural
8825
Southern Appalachian
1990-05-01
C
2 -Nigh
G1G2
SiS2
Community
Bag (Low Elevation
Subtype)
Reptile
17709
Crotalus horridus
Timber Rattlesnake
1961-08-12
H
4 -Low
Special
G4
S3
Concern
Vascular Plant
17286
Arisaema stewardsonff
Bog Jack-in-the-pulpit
2000-05-26
C
2 -High
-
Significantly
G5T4T
S2
Rare Peripheral
5
Vascular Plant
23822
Danthonia epilis
Bog Ostgrass
1996
E
2 -High
—
Significantly
G3G4
S3
Rare
Throughout
Vascular Plant
25164
Dendrolycopodium
Prickly Ground -pine
1994-D4
AC
3 -Medium
Significantly
G5
S2
dandroideum
Rare Peripheral
Vascular Plant
10448
Packera millefolium
Divided -leaf Ragwort
2014-11-24
8
3 -Medium
Species of
Threatened
G3
S2
Concern
Vascular Plant
16868
Packera millefolium
Divided -leaf Ragwort
1992-07-19
D
3 -Medium
Species of
Threatened
G3
S2
Concern
Vascular Plant
10376
Packera millefolium
Divided4eaf Ragwort
1983-08-04
C
3 -Medium
Species of
Threatened
G3
S2
Concern
Vascular Plant
28042
Packera millefolium
Divided4eaf Ragwort
2009-06-02
D
2 -High
Species of
Threatened
G3
S2
Concern
Vascular Plant
9214
Rhododendron vaseyf
Pink -shell Azalea
2015-06-03
A
3 -Medium
Significantly
G3
S3
Rare Limited
Vascular Plant
37
Robinia hartwigii
Hartweg's Locust
1992-07-19
C
3 -Medium
Species of
Significantly
G3T2
SiS2
Concern
Rare Limited
Vascular Plant
34538
Solidago simulans
Granite Dome Goldenrod
2013-07-25
C
3 -Medium
Species of
Significantly
G2
S2
Concern
Rare Limited
Page 4 of 6

Eiement Occurrences Documented Within a One -mile Radius of the Project Area
up Observation Occurrence Status Status
Vascular Plant 29312 Solidago simurans Granite Dome Goldenrod 2014-11-05 E 3 -Medium S ci f S" 'r
Vascular Plant 35441
Trichophoruin cespitosumDeerhair Bulrush
V- es o Ignt (cantly
Concern Rare Limited
2015-06-03
Natural Areas Documented Within a One -mile Radius of the Project Area
Horsepasture River Flats
R5 (General)
Nix Mountain
R5 (General)
Dillard Canyon and Cliffs
R11 (Exceptional)
High HamptonlChatiooga Ridge Natural Area
R3 (High)
Timber Ridge
R5 (General)
Little Terrapin Mountain Cliffs
R2 (Very High)
a � n T: _ ..
ane ed Areas Documented Within aOna-mile Radius of the Pro)ect Area
Nantahala National Forest - Nantahala Ranger District US Forest Service
NC Division of Mitigation Services Easement NC DEQ, Division of Mitigation Services
Highlands -Cashiers Land Trust Easement Highlands -Cashiers Land Trust
Chatiooga National Wild and Scenic River US Forest Service
Sanson Wildlife Sanctuary Humane Society Wildlife Land Trust
2 -High -- Significantly
Rare Disjunct
C5 (General)
C4 (Moderate)
C3 (High)
C3 (High)
C4 (Moderate)
C3 (High)
Federal
State
Private
Federal
Private
Rank Rank-'
G2 S2
G5 S2S3
Deffnitions and an eVianallon of status designations and Godes can be found at . Data query generated on January 16, 2D18; source; NCNHP, Q4 October 2017. Please resubmit
your information request if more than one yeaT elapses before project ini8atlon as new Information Is continually added lo the NCNHP database.
Page 5 of 6

January 10, 2018
❑ Project Boundary
❑ Buttered Project Boundary
NHP NaturalAre. (NMNA)
Managed Area (MAREA)
NCNHDE-5083: High Hampton
Page 6 of 6
AV,/
L
a 0.325 0,115 1.3 rrw
0 0.5 1 2 k
—P—=
MO. EM a
N.
'Jkm
N
January 10, 2018
❑ Project Boundary
❑ Buttered Project Boundary
NHP NaturalAre. (NMNA)
Managed Area (MAREA)
NCNHDE-5083: High Hampton
Page 6 of 6
AV,/
L
a 0.325 0,115 1.3 rrw
0 0.5 1 2 k
—P—=
MO. EM a

-,.N
Northern Long -Eared Bat Consultation Arras
Jackson County
0 North Carolina County Boundary
Watersheds with Known NLEB Maternity frees or Hibernation Sites
If your project falls within
the red areas identified in
Jackson County, please
contact the CISFWS
0 5 Miles
4t l USFWS Ecological Services
Asheville Field Office.
I Asheville, North Carolina
0 5 Kilometers Map Date: 213!2016
TN
13A
NC