20180765 Ver 1_More Info Received_20181101

Mr. David Brown
10/30/18
Page 2 of 10
Please reference Attachment B for High Hampton’s correspondence pertaining to ongoing
construction and Chattooga Lake.

Highlands-Cashiers Land Trust – Comment #1 – “Page 7, paragraph 4, sentence 2: The Purple
Mountain Pitcher (Saracenia purpurea var montana) plant was previously documented by the
Highlands-Cashiers Land Trust not the Southern Appalachian Highlands Conservatory
(Highlands Conservatory).”

We agree with this comment. The purple mountain pitcher plant was documented by the
Highlands-Cashiers Land Trust.

Highlands-Cashiers Land Trust – Comment #2 – “Page 7, paragraph 4, sentence 4: It is our
understanding that the conservation easement will be with an easement held by the Highlands-
Cashiers Land Trust, not the Southern Appalachian Highlands Conservatory (Highlands
Conservatory).”

This statement is correct, the Applicant has proposed that the Highland-Cashiers Land
Trust hold the conservation easement.

Highlands-Cashiers Land Trust – Comment #3 – “Any buffers around protected wetlands and
streams should be a minimum of 30ft but 50-100ft would minimize future potential impacts to these
protected areas.”

The on-site stream preservation plan proposed for the project complies with The Mitigation
Rule as outlined in the “Use of Stream 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. The requested buffer size
(100 feet along perennial streams and 50 feet along intermittent streams) would eliminate
potential residential lots and require that all lots with buffers would be owned by individual
homeowners instead of one POA control. In addition, the Applicant would receive an
addition 16% percent mitigation credit for buffer that exceed 75 feet (Wilmington District
Stream and Wetland Compensatory Mitigation Update – North Carolina Interagency
Review team – October 24, 2016)

Chattooga Conservancy – Comment #1 – Alternatives – “We request that the applicant provide
more details regarding avoidance and minimization of stream and wetland impacts for this
project; specifically, why the particular impact cannot be practically accomplished, reduced or
reconfigured to avoid impacts to the stream or wetland. Examples of avoidance or minimization
actions may be retaining walls for stabilization, minor hole reconfigurations, avoidance of impacts
between holes, options for play over of streams/wetlands, alternative road access configurations,
etc.”

In response to agency concerns, the Applicant has engaged in further review of the planning
for the development with its various consultants to determine what, if any, further
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10/30/18
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modifications might be undertaken to enlarge the avoidance envelope or further minimize
impacts to wetland/stream resources. Based on that review and the Applicant’s desire to
be as responsive as possible to the regulatory concerns for permitting this project, the
Applicant proposes the following adjustments:
• The Applicant has reduced golf course impacts by avoiding an additional 1,080
linear feet of stream and 0.006 acre of wetland by adjusting the site layout. The
Applicant has continued to review and make adjustments to the individual holes
that do not compromise the golf course and provide the most avoidance as possible.

• Golf design revisions eliminated Stream Impact #1, Stream impact #2, Stream
Impact #15, Wetland Impact #10, and Wetland Impact #16 from the golf course.
Redesign also reduced golf course impacts, including Stream Impact #3 from 110
linear to feet 55 linear feet, Stream Impact #4 from 106 linear feet to 53 linear feet,
and Stream Impact #14 from 200 linear feet to 100 linear feet.

• Impacts associated with bank stabilization have been reduced from 600 linear feet
to 300 linear feet.

• The Applicant has also reduced road impacts by avoiding an additional 141 linear
feet of stream. After further evaluation of the road design by WGLA Engineering,
the road culvert associated with Stream Impact #13 (72 linear feet of stream impact)
was eliminated and Stream Impact #21 was reduced from 98 linear feet to 75 linear
feet. WGLA Engineering also determined that a bridge could be utilized for Stream
Impact #5 (46 linear feet of stream impact). There are seven total bridges that could
be feasibly constructed and are proposed for the redevelopment project. Overall,
the use of seven bridges on-site avoids approximately 280 linear feet of stream
impacts.

Total permanent stream impacts for the entire project have been reduced by 40 percent,
from 2,693 linear feet of stream to 1,613 linear feet of stream impact. Permanent wetland
impacts have been reduced from 0.760 acre to 0.754 acre of impact. An updated site plan
(Figure 5.0, revised 8-30-18) is included in Attachment C.

These changes and additional alternative analysis information was submitted to the US
Army Corps of Engineers and the NC Division of Water Resources on October 1, 2018.

Chattooga Conservancy – Comment #2 – Stormwater – “We request that the applicant provide
a stormwater control plan. 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). 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.”

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
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10/30/18
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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.

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 the NC Division of Water Resources (DWR). The
stormwater management plan will be approved prior to impacts to streams.

Chattooga Conservancy – Comment #3 – Wastewater – “To evaluate indirect effects from the
proposed projects 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 the project’s
impact associated with tying into this plant.”

Only the existing wastewater capacity currently used from Tuckaseigee 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 system and land application
system that will utilize 5 drip irrigation fields located throughout the development.
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10/30/18
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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.

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.

Chattooga Conservancy – Comment #4 – Chattooga Ridge Development – “We are 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.
We encourage the applicant to omit or reduce development activities in this area in the interest of
protecting the unique habitats in this area.”

The Applicant has carefully designed the redevelopment of High Hampton to avoid and
minimize impacts. The low-density residential development on Chattooga Ridge avoids
any impacts to streams and wetlands. 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). The development will also comply with N.C. ORW rules and provide
stormwater treatment for the project as required by 15A NCAC 02b .0225. Approximately
158 acres of Chattooga Ridge is already placed in a conservation easement for long-term
protection.

Public Comment #1 – Susan P. Davis – “I am concerned about the redevelopment of High
Hampton resort affecting the wetlands short term and long term because of the proposed golf
course. Golf courses require a lot of fertilizer and other chemicals to maintain. I am concerned
about the chemical runoff into sensitive wetlands that are home to many birds, mammals and
reptiles that are unique to our area.”

The majority of the land proposed for golf renovations has been utilized as a golf course
since the 1920s. The course will continue to operate in a similar manner and will use
pesticide and fertilizer safely as prescribed by the manufacturer. Additionally, High
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10/30/18
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Hampton will adhere to the following principles outlined in “Environmental Principles for
Golf Courses in the United States” (The Center for Resource Management, 1996):

Plant Protection and Nutrition
1. Employ the principles of integrated plant management, a system that relies on a
combination of common-sense practices of preventing and controlling pests (e.g.,
weeds, diseases, insects) in which monitoring is utilized to identify pests, damage
thresholds are considered, all possible management options are evaluated, and selected
control(s) are implemented. IPM involves a series of steps in the decision-making
process:
a. Through regular monitoring and record keeping, identify the pest problem,
analyze the conditions causing it, and determine the damage threshold level
below which the pest can be tolerated.
b. Devise ways to change conditions to prevent or discourage recurrence of the
problem. Examples include: utilizing improved (e.g., drought resistant, pest
resistant) turfgrass varieties, modifying microclimate conditions, or changing
cultural practice management programs.
c. If damage thresholds are met, select the combination of control strategies to
suppress the pest populations with minimal environmental impact, to avoid
surpassing threshold limits. Control measures include biological, cultural,
physical, mechanical, and chemical methods. Biological control methods must
be environmentally sound and should be properly screened and tested before
implementation.

Non-chemical control measures should focus on practices such as the introduction of
natural pest enemies (e.g., parasites and predators), utilizing syringing techniques,
improving air movement, soil aerification techniques, and mechanical traps. The
selection of chemical control strategies should be utilized only when other strategies are
inadequate.

When chemical and nutrient products need to be applied, the following practices should
be utilized:

2. Always read and follow label directions when using any plant protectant products. Strive
to treat problems at the proper time and under the proper conditions to maximize
effectiveness with minimal environmental impact. Spot treatments may provide early,
effective control of problems before damage thresholds are reached.
3. Store and handle all pest control and nutrient products in a manner that minimizes worker
exposure and/or the potential for point or non-point source pollution. Employ proper
chemical storage practices and use suitable personal protective equipment and handling
techniques.
4. Use nutrient products and practices that reduce the potential for contamination of ground
and surface water. Strategies include: use of slow-release fertilizers, selected organic
products, and/or fertigation.
5. Test and monitor soil conditions regularly and modify practices accordingly. Choose
nutrient products and time applications to meet, not exceed, the needs of the turfgrass.
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10/30/18
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6. All plant protectant products should only be applied by or under the supervision of a
trained, licensed applicator or as dictated by law.
7. Maintain excellence in the continuing education of applicators (including state licensing,
professional association training and IPM certification). Training for non-English
speaking applicators should be provided in the worker's native language.
8. Facilities should inform golfers and guests about golf course chemical applications.
Common methods include permanent signs on the first and tenth tee boxes and/or
notices posted in golf shops and locker rooms.

Water Usage
1. Use native, naturalized or specialized drought-tolerant plant materials wherever
possible. For areas in play (greens, tees and fairways), using plant materials that: are
well-adapted to local environmental conditions; can be efficiently managed; and
provide the desired playing characteristics.
2. Plan irrigation patterns and/or program irrigation control systems to meet the needs of
the plant materials in order to minimize overwatering. When feasible, use modern
irrigation technologies that provide highly efficient water usage. Inspect systems
regularly for leaks and monitor water usage.
3. Water at appropriate times to minimize evaporation and reduce the potential for
disease.
4. Consider converting to effluent irrigation systems when available, economically
feasible and agronomically and environmentally acceptable.
5. Manage water use effectively to prevent unnecessary depletion of local water
resources.

Waste Management
1. Leave grass clippings and other organic materials in place whenever agronomically
possible. If clippings are removed, compost and, if possible, recycle them.
2. Dispose of chemical rinsate in a manner that will not increase the potential for point or
non-point source pollution. Methods include rinsate recycling or "spraying out" diluted
compound in previously untreated areas.
3. Dispose of chemical packaging according to label directions (e.g., triple rinsing,
recycling or returning to manufacturer).
4. Other waste products, such as used motor oil, electric batteries and unused solvents,
should be recycled or disposed of according to the law and available community
disposal techniques.
5. Seek to reduce waste by purchasing products that minimize unnecessary packaging.

Wildlife Management
1. Habitat for wildlife species that help control pests (e.g., bats, bluebirds, purple martins,
etc.) should be protected. Additional habitat for these beneficial species should be
created whenever feasible and environmentally desirable.
2. Manage habitat to maintain healthy populations of wildlife and aquatic species.
3. Species such as skunks, non-migratory Canada geese, and deer, when they become
damaging, should be managed through nonharmful means whenever possible.
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Nonharmful control methods could include dogs, noisemakers, repellents, and trapping
and removal. Managed hunting may be appropriate where legal and safe.

Facility Operations
1. Facilities should conduct an environmental assessment in order to develop and
implement an overall environmental policy and/or long-range plan that reflects or
expands upon these principles.
2. Maintain ongoing records to measure and document progress toward environmental
improvement.
3. The environmentally responsible practices adopted for the maintenance of the golf
course should extend to all areas of the overall facility grounds.
4. Facilities should adopt practices and technologies that conserve natural resources,
including water and energy.
5. Facilities should develop and initiate comprehensive programs for recycling, reuse and
waste reduction.
6. Facilities should properly store and dispose of solvents, cleaning materials, paints and
other potentially hazardous substances.
7. Facilities are urged to join programs that help to foster effective environmental
management and policies.
8. Facilities should take active steps to educate golfers, neighbors and the general public
about their environmental policies and practices.

Public Comment #2 – Susanne Cole Wean – “I have read the public notice and as far as I can
tell it only appears to address the golf course impact on the stream and the lakes. While those are
of importance, I am concerned that the expansion of the golf course is going to lead to additional
home sites which will have a major impact on water usage and quality in the same area as the golf
course expansion... All of this will provide runoff and build up of silt which will change the ecology
of the stream and the lake prior to reaching Fowler Creek and the Chattooga River. The water
system will need to be able to handle this tremendous expansion.”

The Applicant had all streams and wetlands delineated and verified by the USACE
(January 26, 2018) prior to any construction. At this time, construction and land
disturbance activities have occurred only in upland areas. Additionally, a sediment and
erosion control plan for these activities was approved prior to the beginning of work by
Jackson County on February 27, 2018. Inspection logs by WGLA Engineering and Steve
Beasley, the Land Development Administrator for Jackson County, indicate that the site is
in compliance.

The Applicant has also proposed the use of stream preservation buffers for the streams that
flow into High Hampton Lake. The establishment of these buffers helps to preserve and
maintain water quality within on-site streams and the overall watershed in perpetuity.

Please reference Chattooga Conservancy – Comment #2 – Stormwater for additional
details.

Mr. David Brown
10/30/18
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“As an additional concern, I did not read anything about the use of chemicals on the golf course
which run off and is detrimental to plant and animal life.”

Please reference Public Comment #1 – Susan P. Davis.

“Tonight when I took a shower the water was brown and it stained my towel. This is the second
time in the past few weeks that our cold water tap has produced brown water! I am afraid to cook
with this water and having lived here for almost 60 years I know there have been frequent water
problems. I saved some of it in a jar so it can be tested if you are interested, but it makes me
wonder how the system will be able to handle doubling the resident population at High Hampton.”

High Hampton has no plans to monitor drinking water wells on adjacent properties.
Utilities, including water, would be tied in to the existing infrastructure at High Hampton.
No impacts to potable water are anticipated as a result. Several factors, including pipe
corrosion from mineralization or rust, can influence the color of water from a home owner’s
faucet.

Public Comment #3 – Tyler Wean – “…I would like to request a public hearing take place on
this application to determine if the proposal or a practicable alternative is in the public interest.
It is the Chattooga watershed’s superlative environmental and aesthetic quality that makes this
area so desirable for development. For that reason, it is critically important that each and every
developer be held to the same high standard necessary to provide, collectively, for the protection
of the area’s environmental amenities and ecosystem services.”

“It is not clear that this applicant understands or intends to meet the high standard needed to
responsibly develop land in the National Wild & Scenic Chattooga River watershed.”

The Applicant is aware and respects the high standard required for development in the area.
As such, the Applicant has paid acute attention to the avoidance and the minimization of
impacts associated with wetland and stream resources. Likewise, the preservation of these
resources has also been a priority. As a result, the Applicant will preserve 23,355 linear
feet of stream with at least 30-foot buffers on both sides of the stream channel, totaling
approximately 31 acres of upland buffers. Preservation of on-site wetlands will also occur,
totaling 21.645 acres.

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). The development
will also comply with N.C. ORW rules and provide stormwater treatment for the project
as required by 15A NCAC 02b .0225.

Please reference Chattooga Conservancy – Comment #1 – Alternatives for additional
information.

Public Comment #4 – Thomas Davis – “Given the importance of the headwaters of the
Chattooga River and the Horsepasture River and other tributaries which are currently in pristine
Attachment A

Chattooga Forest Association (CFA) – July 10, 2018

Highlands-Cashiers Land Trust – July 16, 2018

Chattooga Conservancy – July 16, 2018

&

Additional Public Notice Comments – July 12-July 17, 2018

Attachment B

Alston & Bird

Golf Course Renovations at High Hampton

August 10, 2018

Attachment C

Revised Stream & Wetland Impact Map (Figure 5.0, Revised 8-30-18)