Loading...
HomeMy WebLinkAbout20180582 Ver 2_Response to Chattooga Conser and Public Comments_20190418Staff Review Does this application have all the attachments needed to accept it into the review process? r Yes r No ID#* Version* 2 20180582 Is this project a public transportation project?* r Yes r No Reviewer List:* Kevin Mitchell:eads\rkmitchell Select Reviewing Office:* Asheville Regional Office - (828) 296-4500 Submittal Type:* Application Attachments Does this project require a request for payment to be sent?* r Yes r No Project Submittal Form Please note: fields marked with a red asterisk below are required. You will not be able to submit the form until all mandatory questions are answered. Project Type: r New Project r Pre -Application Submittal r More Information Response r Other Agency Comments r For the Record Only (Courtesy Copy) New Project - Please check the new project type if you are trying to submit a new project that needs an official approval decision. Pre -Application Submittal - Please check the pre -application submittal if you just want feedback on your submittal and do not have the expectation that your submittal will be considered a complete application requiring a formal decision. More Information Response - Please check this type if you are responding to a request for information from staff and you have and ID# and version for this response. Other Agency Comments - Please check this if you are submitting comments on an existing project. Is this supplemental information that needs to be sent to the Corps?* r Yes r No Project Contact Information Name: Kaylie Yankura Who is subrritting the information? Email Address: kaylie@cwenv.com Project Information Existing ID #: Existing Version: 20180582 1 20170001 (no dashes) Project Name: Cashiers Canoe Club Development Is this a public transportation project? r Yes r No Is the project located within a NC DCM Area of Environmental Concern (AEC)? r Yes r No r Unknown County (ies) Jackson Please upload all files that need to be submited. Click the upload button or drag and drop files here to attach docurrent 508—Cashiers Canoe Club Development—Response 4.92MB to Chattooga Conser and Public Comments.pdf Only pdf or Igre files are accepted. Describe the attachments: Attached is the Response to Chattooga Conservancy and Public Comments letter submitted on behalf of Canoe Club Development. V By checking the box and signing box below, I certify that: • I have given true, accurate, and complete information on this form; • I agree that submission of this form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act") o I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act'); • I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written signature; AND o I intend to electronically sign and submit the online form." Signature: CIl�L�'. �� ��df6�llttl Submittal Date: Is filled inautorretically. CLearWater C1earWater Environmental Consultants, Inc. www.cwenucom April 15, 2019 Mr. David Brown US Army Corps of Engineers Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-2638 RE: Cashiers Canoe Club Development Response to Chattooga Conservancy & Public Comments Jackson County, North Carolina Action ID SAW -2016-00032; DWQ Project # 2018-0582 Dear Mr. Brown, Please reference Attachment A, which contains letters from the Chattooga Conservancy (June 8, 2018), Highlands -Cashiers Land Trust (June 8, 2018), and public comments (May 10 -June 14, 2018) received in response to the permit application submitted by C1earWater Environmental Consultants, Inc. (CEC) on behalf of the Cashiers Canoe Club Development (Applicant) represented by Ms. Roseanne Giordani. The permit application requested written authorization for impacts associated with the maintenance dredging of the existing Cashiers Lake and associated mixed-use development. The comments provided by the Chattooga Conservancy, as well as those received during the public review period, have been categorized by topic and are discussed below. Chattooga Conservancy — Comment #1— Need for A Public Hearing — "This project should not be approved without a public hearing to determine if the proposal or a practicable alternative is in the public interest. " The North Carolina Division of Water Resources (DWR) has decided to conduct a public hearing for the proposed project. Details regarding the meeting time and date will be set by DWR. "Another important reason thatACE should grant a public hearing is related to the administration of the Wild & Scenic Rivers Act ... In the event that the Forest Service fails to make comments on this important issue concerning the application for dredging and filling in a water body that feeds the headwaters of the ff'ild & Scenic Chattooga River, and associated land disturbing activities for commercial real estate development and related point and non point source discharges that will affect the Chattooga River, then an important piece of information that is critical in the public decision-making process is lacking, and the public has a right to know the Forest Service's position as mandated by law. " 32 Clayton Street Asheville, NC 28801 828-698-9800 Tel Mr. David Brown 4/15/2019 Page 2 of 10 The Forest Service has not provided comments during the public review period or to date. Chattooga Conservancy — Comment #2 — The Applicant's Proposal Fails to Articulate Alternatives or Provide a Realistic Baseline for "No Action" — "Cashiers Canoe Club has not shown a lack of practical alternatives. An Applicant must demonstrate that alternative designs with fewer impacts cannot meet the "basic project purpose. " ... According to the application, the basic project purpose here is as follows: "The overall project purpose is to conduct maintenance dredging of Cashiers Lake to restore historic open water conditions. "" The primary purpose for the lake dredging is lake maintenance resulting from years of deposits of sediment from upstream. As shown in historical aerial photographs, the size of the lake has reduced significantly from these impacts, and it will most likely continue unless efforts are made to remove the sedimentation on a more regular basis. "The basic project purpose could certainly be met with fewer impacts. Most obviously, this project purpose does not require the construction of roads associated with a future high-density development including a 100 -room resort hotel, a 55 -home subdivision and other buildings and amenities, nor the bulkheads that will allow shoreline development... " Impacts associated with previously proposed road crossings (Impact #6, Impact #7, Impact #8, and Impact #8A) have been eliminated due to the proposed use of bridges within these areas. The Applicant has removed the hotel from the project and has instead replaced this component with a proposed residential development consistent with plan approved in 2009. Proposed bulkheads located at Impact #2 and Impact #5 would be utilized for on-site storage of dredged material. Allocating approximately 1.39 acres of dredged waste material (approximately 14,000 cubic yards) for the use of bulkheads provides a means of disposal within the immediate vicinity of dredging activities. As a result, off-site disturbance would be reduced by using bulkhead construction, and the acreage of material requiring removal to the proposed dredge material waste area would be reduced, which will also reduce costs. These areas would also provide additional access points to the lake for passive recreation (canoeing, fishing, swimming, etc.). The proposed bulkheads also serve a function from an operation standpoint as well. Installation of the bulkhead associated with Impact #11 (Figure 3.0, Attachment B) would protect banks from shoreline erosion and assist in maintaining an open channel from where the headwaters of the Chattooga River flow into the lake and contribute significant amounts of sediment. The use of bulkheads will allow room to grade between the steeper terrain to the west and the lake. This graded area will be used for future dredging access from high ground as well as part of the walking trail network and fishing access. "It is also difficult to see how a quarter -acre of wetland impacts for a parking lot would serve the project purpose. " Mr. David Brown 4/15/2019 Page 3 of 10 The proposed sales center and parking have been removed from this area. Impact #13 totals 0.36 acre of wetland impact and would be utilized instead for proposed forebay access and construction. The previous property owner routinely maintained this area as an herbaceous wetland. Chattooga Conservancy — Comment #3 — The Applicant's Proposal Improperly Segments a Larger Plan of Development — the dredging is ancillary to an inchoate, unanalyzed, and unmitigated project purpose — building a high-density development with hotel and subdivision. The applicant strains credibility by suggesting that dredging would be undertaken regardless of whether the development is built. " If dredging is not conducted, the lake will continue to fill in with sediment and eventually, there would be no lake. Following dredging, the lake will continue to accumulate sediment. The Applicant needs to conduct maintenance dredging in order to have a lake and would be pursuing dredging with or without adjacent development. It is important to note that there are no stream or wetland impacts associated with residential lots, development of roads, or utilities. "The applicant is therefore attempting to segment a larger development plan, seeking approval for initial development of infrastructure that will make future development a forgone conclusion, but avoiding disclosure of the full extent of the future development's impacts. " There has been no attempt to segment a larger development plan or avoid the disclosure of the full extent of future development impacts. All proposed impacts to jurisdictional features have been identified and minimized to the extent practicable. There are currently no plans for the areas identified as "future development," however, these portions of the parcel are in uplands and future development will not impact jurisdictional features. The Applicant will comply with the state stormwater ORW rules for development within these areas as well. Chattooga Conservancy — Comment #4 — Impacts to Downstream Values — "it claims "no significant effect" to normal water fluctuations, despite the increase in impervious surface that will be caused by high-density development on a headwater stream of the National Wild & Scenic Chattooga River. It acknowledges only "minor short term" cumulative impacts, ignoring the impacts of the development itself, which will be numerous: chronic erosion and sedimentation runoff during the construction of the nebulous 'future development, " household and commercial detritus washing into a wild and scenic river corridor, oil and other chemical runoff from parking lots; a significant increase in human waste that will ultimately be discharged into the Chattooga; loss of wetlands that serve to reduce downstream pollution and flashiness; decrease in dissolved oxygen that will negatively impact aquatic life; and, likely, many other negative impacts that would be inevitable with the proposed project. " The Applicant will design the site to comply with NC ORW stormwater rules (I 5A NCAC 02H.1021). Mr. David Brown 4/15/2019 Page 4of10 A stormwater management plan for the residential areas identified on Figure 3.0 and as DA 41 on Sheet C2-00 was submitted by LandDesign on April 9, 2009 and was approved on May 14, 2009 under Stormwater Permit No. SW 1080801. Stormwater plans for DA #2 will be submitted following approval of the 401 Water Quality Certification. Areas identified as DA #3, DA #4, and DA #5 do not have plans yet for future development. If/when those areas are developed, the Applicant will comply with stormwater management regulations. Chattooga Conservancy — Comment #5 — Failure to Acknowledge Need for Extraordinary Stormwater Measures — "The Applicant states that the project will comply with local ordinances and OR rules, but the application's brief discussion of Best Management Practices (BMP) does not show how this could possibly be true. " In response to agency and public concerns, the Applicant has engaged in additional review of the proposed project. LandDesign is now the civil engineer for the project development and has provided new input on previously designed and submitted site plans. Based on this collective review, the Applicant proposes the following adjustments: • Impacts associated with previously proposed road crossings (Impact #6, Impact #7, Impact #8, and Impact #8A) have been eliminated due to the proposed use of bridges within these areas. • The Applicant proposes the installation of a pond forebay. The forebay would provide upland access for future lake maintenance/dredging activities and would assist in reducing future siltation of Cashiers Lake. • To accommodate pre and post -construction equipment access and staging from Frank Allen Road to the proposed forebay, the Applicant proposes a 0.12 acre increase on Impact #13 from 0.24 acre to 0.36 acre. • Proposed dredging Impact #10 has been reduced by 0.21 acre and Impact #12 has been reduced by 0.18 acre. • The proposed dredginglimpact from the lake bed has been reduced from 17.37 acres to 3.34 acres, which is a reduction from 77,000 cubic yards to 36,500 cubic yards. • The Applicant proposes to utilize a temporary diversion ditch to redirect incoming stream flow within the proposed wetland dredge area. Cashiers Lake would be drawn down via a mechanical pump to four feet below the normal pool elevation (from approximately 3,471 feet to 3,467 feet) during construction activities. A siphon would also be utilized to draw down water within the lake after rain events. The use of turbidity curtains within Cashiers Lake is also proposed. LandDesign also conducted an on-site meeting with Mr. Stan Aiken of the Division of Energy, Mineral, and Land Resources (DEMLR) on October 9, 2018 and has made several revisions to the previously submitted site and erosion/sediment control plans. These changes are reflected within the Cashiers Lake Dredging Plan (submitted to USACE on November 19, 2018). A finalized Erosion Control Plan will be submitted for approval by DEMLR. The approved plan and associated documentation will be provided to the NC Division of Water Resources as well. This plan will comply with N.C. ORW rules. Mr. David Brown 4/15/2019 Page 5 of 10 The original dredging plan has also been revised by LandDesign. The construction sequence is included on Sheet C3-02 of the Cashiers Lake Dredging Plan. Dredging activities will occur in an upstream to downstream direction. The use of turbidity curtains and a temporary sediment basin have been incorporated into the project as shown on Sheet C3-00 (Attachment C). A proposed Turbidity Monitoring Plan is included within the Erosion Control and Master Stormwater Narrative section of the Cashiers Lake Dredging Plan. The contractor will coordinate work with rain events. Dredging work will be suspended until the lake is sufficiently drawn down. Proposed construction activities will not occur during large and/or prolonged precipitation events. Sediment and erosion control plans and practices will comply with ORW stormwater rules for sensitive watersheds. "Perhaps the Applicant is thinking of the basic requirement to control 1 inch of rainfall from high- density developments in OR watersheds. The applicable Jackson County ordinance, however, requires detention and control of a 25 year, 24-hour storm event. According to information available from NOAA, such an event would produce between 9 and 11 inches of rain in Cashiers. The Applicant's plans do not make room for the structures that would be needed to adequately manage this amount of rainfall. " Section 10-1.c of the Cashiers Commercial Area Land Development Ordinance states that "The property owner and/or developer shall provide a stormwater management plan that accommodates run-off generated by a ten-year, 24-hour rain event or, if the property is located within a designated Outstanding Water Resource Area, the 25 -year storm. Stormwater measures shall be designed to remove, at a minimum, 85 percent of the total suspended solids (TSS) from the first inch of rainfall of any event. Stormwater measures shall have a drawdown of at least 48 hours, but not more than 120 hours." The master stormwater plan for the proposed project will provide BMP measures in the manner of infiltration chambers that provide a minimum of 85 percent TSS from the first in of rainfall in any event, along with stormwater facilities that will be designed to handle a 25 -year storm. Chattooga Conservancy — Comment # 6 — The Applicant's Mitigation Plan is Legally and Practically Inadequate — "The mitigation described in the application is utterly inadequate. First of all, there should be much more explanation of the 1:1.5 ratio for wetlands mitigation. Wetlands contiguous to streams designated as OR must be mitigated at a 4:1 ratio for "restoration, " and even higher ratios for enhancement or preservation. " The North Carolina Wetland Assessment Method (NCWAM) utilizes twenty-two field metrics to evaluate the function and sub -function of wetland types and assessment areas applicable to North Carolina. Overall, these field metrics provide qualitative rankings for functions like wetland hydrology, water quality, and habitat. NCWAM rankings are generated via an objective computer-based program and often influence mitigation planning and associated USACE review of proposed mitigation. Mr. David Brown 4/15/2019 Page 6 of 10 Prior to submitting the individual permit application, staff from CEC conducted a field evaluation of wetlands located within Cashiers Lake using NCWAM. Based off field and geographic information systems (GIS) data, the NCWAM computer-based calculator provided an overall ranking of "Low" for these wetland areas. This ranking is the result of many factors, including excessive sedimentation, poor connectivity to the surrounding natural landscape, disruptions caused by artificial edges, and alterations to overbank and overland flow within the assessment area. The NCWAM data was presented to the USACE during on-site meetings and in previous conversations regarding mitigation proposals for the project. At the time, the Corps determined that no mitigation would be required for impacts to wetlands appearing from 1998 -present and that the remainder of wetland impacts would be mitigated for at a compensatory ratio of 1:1.5. However, after additional review of the project, the USACE will now also require compensatory mitigation for impacts occurring to wetlands within the 1998 -present category. The Chattooga Conservancy cites the state guidelines 15A NCAC 02H.0506(h)(7) for wetland mitigation in their correspondence, however, the Federal Clean Water Act (CWA) Section 404(b)(1) Guidelines overseen by the USACE take precedence. It is ultimately the responsibility of the USACE to approve mitigation plans and to determine the appropriate amount and type of compensatory mitigation on a project -by -project basis. "Second, the Applicant offers no mitigation whatsoever for stream impacts. Nor, as explained above, does the Applicant acknowledge what additional stream impacts would result from the `future development, " much less provide mitigation for those impacts. " Impacts associated with previously proposed road crossings (Impact #6, Impact #7, Impact #8, and Impact #8A) have been eliminated. The Applicant has proposed the use of bridges for these two crossings. The installation of culverts at these locations is no longer a project component. "Third, the proposed mitigation does not meet the requirement to locate mitigation in the same sub -basin unless impractical to do so... It appears, instead, that the Applicant intends to pay in - lieu fees to claim credits far wetlands restoration in a totally different basin (Tulula Creep which drains to the Gu f of Mexico via the Little Tennessee). No attempt is made to show how this mitigation could prevent significant degradation of the special aquatic resources that will be impacted in the Chattooga basin ... Indeed, based on the comments submitted by Wildlife Resources Commission on June 6, 2018, it appears that there is a practical option for mitigation in the immediate vicinity of the development... " Both the Wildlife Resources Commission (WRC) and the Highlands -Cashiers Land Trust (HCLT) initially identified a potential mitigation site that was available within Horse Cove for wetland restoration and preservation activities. Representatives for the Applicant have visited this site on three occasions and recently discussed mitigation possibilities with HCLT. After engaging in preliminary evaluations, HCLT informed CEC that the property Mr. David Brown 4/15/2019 Page 7 of 10 was no longer available, as the current land owner intends to continue use of the site as a pasture for horses. Therefore, mitigation is proposed by paying into DMS. Chattooga Conservancy -- Comment #7 — Inadequate Information to Allow Public Input on Compliance with Outstanding Resource Water (ORW) Requirements — "In addition, the application does not provide enough information to inform public comment on the plans for treating human waste that will come from the proposed hotel and subdivision. The application acknowledges it will tie into the nearby sewer collection system that goes to the Cashiers Waste Water Treatment Plant (WWTP), but does not explain how this would not lead to an "expansion" of a discharge into an ORW... " Please reference the attached letter from Tuckaseigee Water and Sewer Authority (TWSA) included in Attachment C. TWSA states "The sewer allocation held by Cashiers Canoe Club Development, LLC and not yet connect to TWSA is part of the sewer allocation that is "Not Realized" at that plant as part of our flow management. This 55,785 Gallons per Day of treatment capacity is thus reserved in the total 200,000 GPD of capacity of the existing Cashiers Waste Water Plant. The future acceptance of this 55,785 Gallons per Day of non -industrial sewage is within the design treatment capacity of 200,000 GPD plant and can be treated to meet the discharge limits as set in the current NPDES Permit NC0063321. No new treatment capacity is needed to accept these flows at the current plant." "Even if the Cashiers WWTP has the theoretical capacity to handle the increased load, violation of National Pollutant Discharge Elimination System (NPDES) permit conditions have already occurred in the past. The Applicant must show why those violations would not be more numerous or serious with the proposed increased load. " Operation and compliance of the WWTP is not the responsibility of the Applicant. The WWTP is a permitted facility by the State of North Carolina and must comply with NPDES requirements as regulated. Chattooga Conservancy — Comment #7 — The Project Cannot Be Allowed to Cause Further Impairment of a ORW — "Further, TWSA intends to boost operations of this WWTP to 100% of its permitted flow, to service approved, realized customer allocations including the applicant... While clearly initiating and "expansion" of a discharge into an ORW, the application fails to disclose how NPDES permit compliance would be achieved by operating the Cashiers WWTP at 100% of its permitted flow. Though TWSA asserts that the Cashiers WWTP has been designed to accommodate up to 400, 000 gallons per day of inflow (sewer plus infiltration during a storm event), this does not account for the face that the excess inflow is often `flash treated" with chemicals and released directly into receiving waters, which most certainly will negatively impact Outstanding Resource Waters. " Included is a letter from the TWSA (Attachment C) dated October 25, 2018 regarding the current inflow capacity. The existing WWTP owned and operated by TWSA will be able to handle the proposed waste water treatment without further expansion of the existing Mr. David Brown 4/15/2014 Page 8 of 10 WNVTP plant located on Cashiers Lake Road. Additional information is provided in the Chattooga Conservancy - Comment 47 above. "Regardless of how much the permit allows as discharge, the actual discharge has been much lower since the Chattooga River was designated OR W. The regulations prohibit expansion of existing discharges, not expansions of existing permits. We doubt that it is lawful to treat slack in the WWTP permit as a property right that can be bought, hanging as a threat over the water quality of a National Wild & Scenic River, whose water quality is supposed to be maintained or improved. " The project will not involve an expansion of the existing WWTP plant or changes to existing permits. "In addition, the Chattooga River in the project area (from source to the Cashiers Lake dam) is potentially impaired for aquatic life due to low dissolved oxygen (DO). DO is caused by impoundment (due to increased temperature, lower surface area interaction, and change in vegetation). Deepening the impoundment and removing the wetlands would exacerbate this violation, which is impermissible in an ORW. " In order to improve downstream water temperatures below the dam, a cold -water release structure was permitted and installed on the existing outlet structure in 2011 during maintenance of the dam (USACE Action ID 2011-00485). "...the Applicant does not explain the proposal's impacts against the "no action" baseline. Without the dredging and development, this lake would continue to naturalize sediment and form wetland habitats until the reservoir falls up, with the Chattooga River restored to surface flow, solving the low dissolved oxygen problem. The Applicant must show how it can at least provide comparable water quality to the "no action " The no action alternative would not result in any impact on the aquatic environment or any other environmental factor. If there is no action, some type of upland land development activity is likely to take place consistent with current land use regulations. The no action alternative would not meet the basic project purpose. Public Comment #1 — Seventy-four comments from concerned citizens were also submitted to the Corps during the public comment review period. Comments from the public were organized by CEC into four categories: waste water treatment; erosion controllstormwater management and impacts water quality; destruction of wetlands, loss of habitat, and land use concerns; and mitigation. It is the opinion of CEC that these issues overlap with those presented by the Chattooga Conservancy and have been addressed within this letter. The Corps received public input from the following commenters, as organized by category: Wastewater Treatment; Marsh Smith, Buzz Williams, Barrett Barker, Gina Goldkuhl, Adam Mobley, Nancy T. James, Nick Terry, Sam Cleary, Jacob Cooper, Tim Ray, Seth Ammons, Erica Ammons, Chanda Morrison, Michael Roy, Rachel Kinback, Dan Pittillo, Charlie Mize, Stiles Tate, Ken Voyles, Kathy Edwards, Harlan Collins, Parker Ammons, Mr. David Brown 4/15/2019 Page 9 of 10 Michael S. Levine, David Dostall, Don Erickson, Karen Lawrence, Thomas Colkett, Marie K. Dunkle, GeoffPage, Abigail Perrin, Martha and Michael Dupuis, Beverly Clary Gerri Tulley, Jim Ward, Angela Ramey, Shane Benedict, Clay Nash, Mary A. Topa, Roger E. Nott, Adam Hackenberg, Chattooga Conservancy/Mountain True, Highlands -Cashiers Land Trust Erosion Control/Stormwater Management & Impacts to Water Quality/Watershed: Buzz Williams, Barrett Barker, Chip Sanders, Adam Mobley, Christine Nadine, Starr Silvis, Nancy T. James, Nick Terry, Ashby Underwood, Sam Cleary, Jacob Cooper, Charles Huyck, Tim Ray, Seth Ammons, Erica Ammons, Chanda Morrison, Michael Roy, Rachel Kinback Matt Nielson, Dan Pittillo, Melissa Welborn, Kimberly Kuchon, David Zietlow, Charlie Mize, Stiles Tate, Ken Voyles, Kathy Edwards, Charlee Tisdale, Doris Cooper, Harlan Collins, Parker Ammons, Michael S. Levin, Kathy Stilwell, Tara Stevenson, David Dostall, Peter Peteet, Preston Oakes, Karen Lawrence, Thomas Colkett, Marie K Dunkle, Elizabeth Lide, Geoff Page, Abigail Perrin, James Riddle, Martha and Michael Dupuis, Bryding Adams, Beverly Clark, Gerri Tulley, Jim Ward, Angel Ramey, Shane Benedict, Mary A. Topa, Roger E. Nott, Adam Hackenberg, Craig Pendergrast, Leah and Bill Horton, Chattooga Conservancy/Mountain True Destruction of Wetlands, Loss of Habitat, & Land Use Concerns: Marsh Smith, Barrett Barker, Gina Goldkuhl, Adam Mobley, Starr Silvis, Nancy T. James, Ashby Underwood, Chevin Woodruff, Derek Enderlin, Sam Cleary, Seth Ammons, Erica Ammons, Taylor Parrish, Michael Roy, Rachel Kinback, Dan Pittillo, Sue Harmon, Melissa Welborn, Kimberly Kuchon, David Zietlow, Charlie Mize, Stiles Tate, Ken Voyles, Kathy Edwards, Charlee Tisdale, Doris Cooper, John Pressley, Parker Ammons, Tara Stevenson, David Dostall, Preston Oakes, Donn Erickson, Karen Lawrence, Thomas Colkett, Marie K Dunkle, Elizabeth Lide, Abigail Perrin, James Riddle, Laurens M. Pitts, Bryding Adams, Gary and Pamela Turnley, Gerri Tulley, Susan May, Jim Ward, Diane Levine, Angela Ramey, Shane Benedict, Clay Nash, Mary A. Topa, Roger E. Nott, Adam Hackenberg, Craig Pendergrast, Leah and Bill Horton, Chattooga Conservancy/Mountain True Mid ag tion: Chattooga Conservancy/Mountain True, Highlands -Cashiers Land Trust Please do not hesitate to contact me at 828-698-9800 if you have any questions or comments. Sincerely, Kaylie A. Y a R. Clement Riddle, P.W.S Project Manager Principal Attachment A — Public Notice Comments Attachment B —Updated Stream & Wetland Impact Map, Figure 3, Revised 4/11/2019 Attachment C — TWSA Letter Copy furnished: Mr. David Brown 4/15/2019 Page 10 of 10 Ms. Sue Homewood — DWR, Winston-Salem Mr. Kevin Mitchel — DWR, Asheville Ms. Andrea Leslie -- WRC Attachment A Public Notice Comments (Sent via Electronic Mail) w UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration NATIONAL MARINE FISHERIES SERVICE Southeast Regional Otnee 26313thAvenue South St Petersburg, Florida 33701-M htip1sermnmi ma.gov May 14, 2018 Colonel Robert J. Clark, Commander USAGE Wilmington District 69 Darlington Avenue Wilmington, North Carolina 28403-1398 Dear Colonel Clark: NOAA°s National Marine Fisheries Service (NMFS) reviewed the project described in the public notice Iisted below. Based on the information in the public notice, the proposed project would NOT occur in the vicinity of essential fish habitat (EFH) designated by the South Atlantic Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS. Present staffing levels preclude further analysis of the proposed work and no further action is planned. This position is neither supportive of nor in opposition to authorization of the proposed work. Notice No. Applicant(s) Notice Date Comment Due Date SAW -2016-00032 Cashiers Canoe Club May 9, 2018 June 8, 2018 Development LLC Please note these comments do not satisfy consultation responsibilities under section 7 of the Endangered Species Act of 1973, as amended. If an activity "may effect" listed species or critical habitat under the purview of the NMFS, please initiate consultation with the Protected Resources Division at the letterhead address. Sincerely, Pace Wilber for Virginia M. Fay Assistant Regional Administrator Habitat Conservation Division N� W(Mr'r%gr/4 'JON 0 6 2018 ® North Carolina Wildlife Resources Commission KN Gordon. Myers, Executive Director June 6, 2018 Mr. David Brown U.S. Array Corps of Engineers, Regulatory Branch 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 SUBJECT: Cashiers Lake Dredge and Development Project Cashiers Lake, Jackson County SAW -2016-00032 Dear Mr. Brown: Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the individual 404 permit application for Cashiers Lake Development's dredging and lake development project, which would impact 6.96 acres of wetland and 18.78 acres of open water in Jackson County. NCWRC biologists have visited the site multiple times. Our comments on this application are offered for your consideration under provisions of the Clean Wager Act of 1977 (33 U.S.C. 466 et. seq.) and Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d). Cashiers Lake Development intends on developing a resort hotel and residential community on the subject property, which includes a 30 -acre lake constructed in 1920, 11.1 acres of which is now wetland. The applicant proposes to restore the historic open water conditions of the lake, dredging 6.54 acres of wetland and 17.37 acres of open water a depth of 3 ft. An additional 0.18 acre of wetland and 1.41 acres of open water would be filled for three bulkheads, and 0.24 acre of wetland filled for a parking area. Future impacts associated with the development are 100 ft of permanent stream impacts and 0.01 acre of wetland fill for culverted road crossings and 30 ft of temporary stream impacts for a sewer crossing. Impacts would be avoided on 5.34 acres of wetland on this site. The Iake will be drawn down with pump and hose or siphon to dredge and to construct the bulkheads. During dredging, the flows will be diverted to the west side of the lake, isolated from the lake bed by a berm, and sent through a temporary sediment removal basin, fitted with baffle curtains and floating skimmer. In addition, the dredging area will be bypassed with flexible pipe that will run from upstream of the lake to the dam; this will be used as needed to maintain minimum flow downstream of the dam. Mailing Address: Habitat Conservation - 1721 Mail Service Center - Raleigh, NC 27699-1721 Telephone: (919) 707-0220 - Fag: (919) 707-0028 s Cashiers Lake Dredging & Development Page 2 June 6, 2018 Cashiers L, Jackson County The Cashiers Lake wetland is unique in its size and placement on the Highlands -Cashiers plateau. Few large wetlands exist on the plateau, and the primarily open shrubby marsh nature of this wetland provides unique habitat for birds, amphibians, and reptiles. Large wetlands like this one are very important as stopovers where migratory birds can rest and refuel, and as overwintering sites. This lake is listed as a birding Hot Spot in eBird, an online bird database. NCWRC has documented Willow Flycatcher (Empidomrx traillii, NC Watch List), a rare bird that prefers wet shrubby areas like the Cashiers Lake wetland, as well as a rich assemblage of common bird species, using this wetland. The northwestern side of the wetland is more forested, and it is characterized by higher floristic diversity, with a mature red maple overstory, shrub understory, and diverse herbaceous layer. Cashiers Lake impounds the Chattooga River, which is classified as an Outstanding Resource Water, and it is 2.5 miles upstream of the Chattooga River Aquatic Habitat, a natural area rated as Very High by the NC Natural Heritage Program due to the richness of rare species it contains. Downstream of the lake, the river contains wild Brown Trout and Rainbow Trout and is a Wild and Scenic River. We offer the following comments on this project: • We are concerned about the extent of the wetland impacts from this project. Almost 7 acres of wetland will be dredged or filled. As described above, this wetland is unique in its size and placement, and it serves as habitat for a diversity of species. We recommend minimizing the amount of wetland to be impacted, prioritizing conservation of the northwestern forested part of the wetland. In addition, 0.24 acres of fill on the northeastern corner of the wetland is proposed for parking; we strongly recommend that this parking be provided at an upland location. • It is extremely important that excellent erosion and sediment control be used for this project to protect the downstream Chattooga River. We recommend that the sediment management strategy during dredging be revised. o The application proposes to divert flows during dredging to a channel on the west side of the lake and pass them through a sediment basin. We are concerned that this scheme will not control turbidity in the outflows sufficiently, and recommend examining the option of pumping flows from the upstream end of the lake to the channel downstream of the dam in order divert flows around the work area. Any option should maintain the hydrology of the wetland that will remain. a The wetland area that will be dredged should be dredged in an upstream to downstream direction, so that sediment can be captured in the downstream wetlands. Sediment curtains also should be used to isolate the dredge and fill areas from open water. o Turbidity of the outflow from the sediment basin should be monitored. We recommend that the applicant work with the NC Division of Water Resources and NCWRC to develop turbidity monitoring methods, turbidity benchmarks, and actions to be taken if excessive turbidity does occur. o If the lake refills from rain events while drawn down, dredging work should be suspended until the lake is sufficiently drawn down. o The dredging will generate approximately 113,000 y& of sediment, which will be spoiled primarily at an upland location. An erosion and sediment control strategy should be developed for this location, featuring silt fence, seeding, and other measures to retain sediment. Cashiers Lake Dredging & Development Page 3 June 6, 2018 Cashiers L, Jackson County • Flows from the dam to the Chattooga River must be maintained at all times, including during lake refill. We recommend that outflows be maintained that are at least 70% of the incoming flows. • A mitigation ratio of 1.5:1 was agreed upon between the applicant and the US Army COrpos of Engineers as needed for impacts to wetlands that developed prior to 1998, which total 5.26 acres. The application proposes to acquire this mitigation through the NC Division of Mitigation Services, which does not have wetland mitigation available in the Savannah River Basin, and would likely use Tulula Bog, a large wetland complex in Graham County and the Little Tennessee River Basin. NCWRC strongly recommends that mitigation be provided on the Highlands -Cashiers plateau, as wetlands in this area have a unique ecology, driven by geology, climate, and faunal and floral characteristics. We are familiar with an impacted Southern Appalachian bog site that has been vetted by the consulting team that is on the plateau; we strongly recommend that this site be acquired as mitigation. • Wetlands that will remain in Cashiers Lake should be put into conservation easement held by a land trust. • The application notes that two stream culverts will be needed on an unnamed tributary {UT} to the Chattooga River, but details on stream crossing type are not included. We recommend against using HDPE material, as this slick material is less likely to hold stream substrate and provide for movement of aquatic organisms like fish and salamanders. • The application also describes the need for a temporary sewerline crossing of a UT to the Chattooga River, and riprap is specified for the stream banks. We recommend against the use of riprap and ask that an alternative of seeding, matting, and native live stakes be used. • Figure 3.1 notes that the existing spillway siphon is to remain in operation throughout the dredging process and used for draining and regulating the lake level. It is unclear how the siphon can remain in operation if the lake will be drawn down. Thank you for the opportunity to review and comment on this project. Please contact me at (828) 803-6054 if you have any questions about these comments. Sincerely, Andrea Leslie Mountain Region Coordinator, Habitat Conservation Program ec: Clement Riddle, C1earWater Environmental Consultants Kevin Mitchell & Sue Homewood, NC Division of Water Resources Byron Hamstead, US Fish and Wildlife Service Lori Williams, Chris Kelly, & Powell Wheeler, NCWRC ° q "JON 0 5 2018 North Carolina Department of Natural and Cultural Resources State Historic Preservation Office Ramona M. Bartos, Administrator Governor Roy Cooper Secretary susi H. Hamilton June 5, 2018 David Brown Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, NC 28801-5006 Office of Archives and FGs" Deputy secretary Kevin Cherry Re: Cashiers I Ake Dredge & Development, Frank Allen Road, Cashiers, SAW 2016-00032, Jackson County, ER 18-1147 Dear Mr. Brown., We have received a public notice concerning the above project. We have conducted a review of the project and are aware of no historic resources which would be affected by the project. Therefore, we have no comment on the project as proposed. The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR Part 800. Thank you for your cooperation and consideration. If you have questions concerning the above comment, contact Renee Gledhill -Earley, environmental review coordinator, at 919-807-6579 or environtmental.review(@ncdcr.gcw In all future communication concerning this project, please cite the above referenced tracking number. Sincerely, 60✓Ramona M. Bartos l.ocatii=109 Rant Jona Stree4 Raleigh NC 27601 MailingAddreas: 4617 Mai[ Service Center. Raleigh NC 27599-4617 Telephme/F= (919) 547-5570/8D74599 United States Department of the Interior FISH AND WILDLIFE SERVICE Asheville Field Office 160 Zitlicoa Street Asheville, North Carolina 28801 June 8, 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: MORTRV W T PF' .............. Subject: Cashiers Lake Dredge and Development Project; Jackson County, North Carolina Log No. 4-2-16-158 The U.S. Fish and Wildlife Service (Service) has reviewed the information provided in the public notice issued May 9, 2018 for the project referenced above. We submit the following comments in accordance with the provisions of the Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661-667e); the National Environmental Policy Act (42 U.S.C. §4321 et seq.); and section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543) (Act). Project Description According to the information provided, The Cashiers Canoe Club Development, LLC is seeking authorizations associated with dredging Cashiers Lake, and the development of a resort hotel (90-100 rooms), residential community (55 lots), and appurtenant facilities and utilities on 89 acres in Cashiers, North Carolina. Specifically, the proposed project would impact 130 linear feet of stream (sewer line and road crossing), 6.96 acre of wetland (fill/dredge) and 18.78 acres of open water (fill/dredge). Cashiers Lake would be drawn down slowly, and the stream it receives would be diverted/isolated from the lakebed during dredging activities. The project occurs in the Tugaloo River subbasin, in the Savannah River basin. Federally Listed Endangered and Threatened Species According to Service records and the Applicant's Threatened and Endangered Species. Assessment (Assessment; dated May 25, 2016), suitable summer roosting habitat is present in the project area for the federally threatened northern long-eared bat (Myotis septentrionalis). However, based on the information provided, the project would occur at a location where any incidental take of northern long-eared bat that may result from associated activities is exempt under the 4(d) rule for this species. Although not required, we encourage the Applicant to avoid tree clearing during the maternity roost season (May 1.5 — August 15) if possible, to further reduce the probability for impacts to this species. The Assessment also indicates that suitable habitat is present onsite for the federally threatened small whorled pogonia (Isotria medeoloides) and swamp pink (Helonias bullata). However, no federally protected species were detected during the Applicant's pedestrian surveys. The Assessment indicates that suitable habitat does not exist onsite for any other listed species. Moreover, Service records show no known occurrences of any other federally protected species or their respective suitable habitats in the proposed project area. Therefore, the Service has no concerns regarding project -mediated impacts to federally protected species at this time. However, obligations under section 7 Act must be reconsidered if: (1) new information reveals impacts of this identified action that may affect listed species or critical habitat in a manner not previously considered, (2) this action is subsequently modified in a manner that was not considered in this review, or (3) a new species is listed or critical habitat is determined that may be affected by the identified action. Project receiving waters support the French Broad River crayfish (Cambarus reburrus). This species occurrence in the Chatooga River represents the entire extent of its known range in the Savannah River basin. This is a federal species of concern, and is not currently afforded legal protection under the Act. However, incorporating proactive conservation measures on its behalf may preclude the need to list it in the future. We offer the following comments in the interest of protecting this species, and other natural resources: Compensatory Mitigration Of the proposed impacts to jurisdictional waters outlined above, required mitigation would be limited to 5.26 acres of wetland. The Applicant proposes to mitigate for wetland impacts at a 1:1.5 ratio citing "low" overall NCWAM scores. Therefore, proposed adjusted compensatory wetland mitigation would total 7.89 acres. Payment would be made to North Carolina Department of Mitigation Services (NCDMS) In -Lieu Fee program. The information provided indicates that NCDMS would accept payment to offset up to 5.15 acres of wetland impacts. However, the USACE Regulatory In -lieu Fee and Bank Information Tracking System website indicates that no mitigation credits are currently available in the Tugaloo subbasin (03060102; website assessed rune 8, 2018). Due to the unique characteristics of this subbasin, which support habitats within the Chatooga River (designated Wild and Scenic), the Service believes it is imperative that compensatory mitigation for the proposed project is carried out within the same subbasin where impacts would occur. The Service is aware of lands within this subbasin that contain bog/wetland habitats supporting rare, conservation priority species that have been proposed for sale in recent years. These lands would likely be suitable for preservation, enhancement, and/or restoration activities. We urge the Applicant to pursue alternatives to the proposed mitigation proposal, and/or ensure that compensatory mitigation stays within the Tugaloo subbasin. Specifically, we recommend that the Applicant coordinate with local land trusts which may be able to assist in this effort. 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 Iimited 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. Dredge spoil should only be disposed in approved locations and should be isolated from stream and wetlands. Road Crossings If 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. The culvert 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 Service appreciates the opportunity to provide these comments. please contact A& Byron Hamstead of our staff at 8281258-3939, Ext. 225, if you have any questions. In any future correspondence concerning this project, please reference our Log Number 4-2-16-158. Sincerely, - - original signed - - Janet Mizzi Field Supervisor e.c. Zan Price; NCDWR Sue Homewood; NCDWR Andrea Leslie; NCWRC Clement Riddle; C1earWater Environmental Consultants, Inc. Water Resources Environmental Quality 0 n le I? Governor COOPER Govetrror y MICHAEL s. REGAN rJUN1 Secretary LINDA CLJLPEPPER ........... lnler•in, Director PV- June 6, 2018 Corps Action ID# SAW -2016-00032 DWR# 20180582 Jackson County David Brown U.S. Army Corps of Engineers Asheville Regulatory Field Office 151 Patton Ave, Room 208 Asheville, North Carolina 28801-5006 Subject Project: Cashiers Canoe Club Development and Dredging Project Dear Mr. Brown: On behalf of the NC Division of Water Resources, we respectfully request that you consider the following comments within your review of the 404 Individual Permit request for the above referenced property: 1. The Division requests that the Individual Permit for the initial dredging and impacts for development infrastructure be approved to occur within 5 years. 2. The Division is concerned that future maintenance dredging may have the potential to disturb wetlands that may establish within the lake and which should be subject to mitigation. If the USACE issues the Individual Permit to allow for the maintenance dredging over a 25 year period as requested,by the applicant, the Division requests that the Permittee be required to submit an updated jurisdictional determination and dredging pian prior to all maintenance dredging activities. The Division also recommends that mitigation be required for any future wetlands that are allowed to develop into a functioning wetland within the 25 year time period. The Division further recommends that no extensions be granted to this permit beyond 25 years. 3. The Purpose and Need for the dredging portion of this project does not clearly detail why the applicant cannot make sufficient use of their property without impacts to the wetlands or with a reduced impact to wetlands. 4. The applicant has not provided a detailed Alternatives Analysis or a detailed avoidance and minimization plan for the development portion of the proposed project. State of NorthCarollm j rwrvimmmeutalQuaHty I WatesRewwm 1617 Ma>7 3eevke CMW i Ralei9b, Nmrth Carolina 276W1617 919 807 6300 Cashiers Canoe Club Development, LLC Corps Action IN SAW -2016-00032 DWR# 20180582 Page 2of2 5. The applicant has not provided a detailed Purpose and Need or an avoidance and minimization analysis for the proposed bulkheads. 6. The development impacts for this project are conceptual; the Division recommends that any approval be contingent upon a defined schedule for development activities. 7. The Division requires mitigation for all wetland impacts, the applicant has not submitted a sufficient mitigation plan to the Division. 8. The proposed project is required to secure an approved Sediment and Erosion Control Plan for the dredging activities, as well as all spoil locations. In addition, the project is subject to the Trout Buffer as regulated by the Division of Energy and Mineral Resources. 9. The applicant should provide a detailed analysis and proposal for protection of downstream water quality and quantity during dredging activities. 10. The Division has requested additional technical information from the applicant and requests that the USACE also consider the attached letter during the review of the application. Thank you for your considering the Division's comments during your review of this Individual Permit. If you have any questions, please contact Sue Homewood at 336-776-9693 or sue.homewood@ncdenr.gov. Sincerely, Karen Higgins, Supervisor 401 & Buffer Permitting Branch cc: Clement Riddle, ClearWater Environmental (via email) Andrea Leslie, NCWRC (via email) DWR ARO DWR — Wetlands and Buffer Permitting Branch Filename; 180582CashiersCanoeClub(Jackson)—404Comments Nantahala Ranger District National Forests in North Carolina 90 Sloan Rd Franklin, NC 28734 TM USDAA United States Forest !' -� Department of Service 'JUN 1018 A')o ■ Agriculture File Code: 1450 David Brown Date: June 6, 2018 USACE Wilmington District, Asheville Office 151 Patton Avenue, Room 208 Asheville, NC 28801 Re: Cashiers Lake Dredge and Development Project Dear Mr. Brown: Our primary concern is any negative impact. to the Nationally Designated Wild & Scenic River Corridor. There is a long standing concern by the public regarding sediment that might be entering the WSR Corridor from an upstream source. Installing and maintaining adequate erosion control is essential. I recommend a contingency plan for managing flood flows, particularly with the by-pass pipe. This contingency plan should provide redundancy in sediment filtration in the event of failure. The sedimentation and erosion control plan also needs to control runoff from the sediment disposal area and sediment from storm water runoff reaching the Chattooga River. As the project is currently proposed, it would have no long-term changes to water temperatures. However, based on the NC Wildlife Resource Commission trout distribution database, there are no trout up or downstream of the lake. The development might consider installing a cold -water intake in the dam to improve stream temperature downstream of the lake. The proposal plans to mitigate wetland loss through the NC Division of Mitigation Services. Given the low number of mountain wetlands, it would be best if those mitigations occurred in the Chattooga River watershed or at least in the mountains in SW North Carolina. Lastly, please consider appropriate minimum flow while the lake is refilling. Sincerel MICHAEL L. WlL K.INS District Ranger Caring for the Land and Serving People PrnW on FWycW P", C�KTTOO f C�NERV David Brown U.S. Army Corps of Engineers Wilmington District—Asheville Regulatory Field Office 151 Patton Ave., Room 208 Asheville, NC 28801-5006 David.W. Brown @usace. a rmy.m 11 Karen Higgins North Carolina Department of Water Resources 512 N. Salisbury St., 9th Floor Raleigh, NC 27604 karen.higgins@ncdenr.gov BY ELECTRONIC MAIL June 8, 2018 Re: Cashlers Canoe Club Development Corps Action ID Number: SAW -2016-00032 Chattooga Conservancy 9 Sequoia Hills Lane Clayton, Georgia 30525 tel. 706-782-6097 lnfogchattoogariver.org iR O TRIT TIP M ;JUN Q 8 2818 j By...................... The following comments are submitted on behalf cif the Chattooga Conservancy and Mountain True, The Chattooga Conservancy is a nonprofit grassroots conservation organization working to protect, promote, and restore the natural ecological Integrity of Chattooga River watershed ecosystems; to ensure the viability of native species in harmony with the need for a healthy huma n environment; and, to educate and empower communities to practice good stewardship on public and private lands. The Chattooga Conservancy has an organizational interest in the proper and lawful management of public and private lands within the Chattooga River watershed, and members, staff, and board members participate in a wide range of recreational activities on these lands. The Chattooga Conservancy represents approximately 600 total members that support our work. MountainTrue is a 36 -year old nonprofit organization that champions clean waters, resilient forests, and healthy communities across Western North Carolina. MountainTrue has members and supporters who live in Cashiers and who recreate on the Chattooga River. I I P a g e 1. Need For Public A Hearing This project should not be approved without a public hearing to determine if the proposal or a practicable alternative is in the public interest. See 15A NCAC 02H.0504. While we respect the applicant's right to reasonably develop the property, that right is limited by the public's shared interest In the Chattooga River watershed's environmental quality. Indeed, 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. There will always be a temptation for individual "free riders" to attempt to share in the common benefits that come from the Chattooga's regulatory protections without meeting its common obligations not to diminish the watershed's unparalleled environmental qualities. Based on the incomplete, self-serving, internally inconsistent, and legally inadequate application, it is not clearthat this foreign applicant understands or Intends to meet the high standard needed to responsibly develop land in the Chattooga watershed. The Army Corps of Engineers (ACE) and North Carolina Department of Water Resources (DWR) should not allow this proposal to proceed without additional information and a public hearing—a genuine opportunity for local residents to learn about undisclosed information pertinent to the permit application and offer informed input. Another important reason that ACE should grant a public hearing is related to the administration of the Wild & Scenic Rivers Act. We note that the head of a federal agency—€n this instance, the U.S. Forest Service—administering the Wild & Scenic Rivers System shall cooperate with the appropriate state water pollution control agencies "forthe purpose of eliminating or diminishing the pollution of waters of the river." 16 USC §1283. The Development Plan for the Chattooga River submitted to the U. S. Congress by the Forest Service notes that the Chattooga Wild & Scenic River Corridor begins only .8 miles below the Cashiers Lake. In the event that the Forest Service fails to make comments on this important issue concerning the application for dredging and filling in a water body that feeds the headwaters of the Wild & Scenic Chattooga River, and associated land disturbing activities for commercial real estate development and related point and non -point source discharges that will affect the Chattooga River, then an important piece of information that is critical in the public decision-making process is lacking, and the public has a right to know the Forest Service's position as mandated by law. A public hearing is an essential forum to inform citizens of the U. S. Forest Service's input, or lack thereof, on the subject application. In short, without more information, real alternatives, and much better mitigation, this project cannot meet regulatory requirements, and it would not be in the public interest. Some of the proposal's more glaring deficiencies are described below. II. The Applicant's Proposal Fails To Articulate Alternatives or Provide A Realistic Baseline For "No Action" 2 1 P a g e Cashiers Canoe Club has not shown a lack of practical alternatives. An applicant must demonstrate that alternative designs with fewer impacts cannot meet the "basic project purpose." 15A NCAC 02H .0506(f). According to the application, the basic project purpose here is as follows: "[Tjhe overall project purpose is to conduct maintenance dredging of Cashiers Lake to restore historic open water conditions." This basic project purpose could certainly be met with fewer Impacts, Most obviously, this project purpose does not require the construction of roads associated with a future high density development including a 100 -room resort hotel, a 55 -home subdivision and other buildings and amenities, nor the bulkheads that will allow shoreline development. It is also difficult to see how a quarter -acre of wetland Impacts for a parking lot would serve the project purpose. Neithdir the Corps nor DWR can approve those impacts based on this application. At most, the agencies may approve only the impacts necessary to accomplish the dredging itself. And, as discussed further herein, even those Impacts may be unlawful. III. The Applicant's Proposal improperly Segments A Larger Plan Of Development Of course, the real purpose of the project Is not solely to restore open water conditions, notwithstanding the applicant's certification that its articulation of the overall project purpose is "true and correct." See 15A NCAC 02H .0502(f). instead, the dredging is ancillary to an inchoate, unanalyzed, and unmitigated project purpose—building a high-density development with hotel and subdivision. The applicant strains credibility by suggesting that dredging would be undertaken regardless of whether the development is built. The applicant is therefore attempting to segment a larger development plan, seeking approval for initial development of infrastructure that will make future development a foregone conclusion, but avoiding disclosure of the full extent of the future development's impacts. The applicant attempts to dodge this critical issue, stating that "Future additional development plans have not been finalized; however, impacts associated with residential and commercial development are limited to 100 linear feet of stream and 0.01 acre of wetlands strictly for the purposes of access via road crossings." But these totals hide all the future impacts that "have not been finalized—impacts that must be considered part of this common plan of development. IV. Impacts To Downstream Values Because It hides the effects of future development behind a false and limited project purpose, the application's disclosure of impacts is self-serving and incomplete. It claims "no significant effect" to normal water fluctuations, despite the increase in impervious surface that will be caused by high-density development on a headwater stream of the National Wild & Scenic Chattooga River. It acknowledges only "minor short term" cumulative impacts, Ignoring the impacts of the development itself, which will be numerous: chronic erosion and sedimentation runoff during the construction of the nebulous "future development," household and commercial detritus washing into a wild and scenic river corridor; oil and other chemical runoff from parking lots; a significant increase in human waste that will ultimately be discharged into the Chattooga; loss of wetlands that serve to reduce downstream pollution and flashiness; decrease in dissolved oxygen that will negatively impact aquatic life; and, likely many other negative impacts that would be inevitable with the proposed project. Some of the application's self-serving statements cannot be squared with information DWR has already gathered on the Chattooga headwaters. For example, the Lipper Chattooga River "is at risk from ... storm water runoff from increasing residential development." See 2008 Savannah River Basin Restoration Priorities. In addition, DWR has noted that sandy conditions and infrequent riffles may be attributed to development activities around Cashiers Lake. See 2012 Management Plan. The applicant's claim that there will he "no impacts" to riffle/pool complexes is therefore unsupported. Strangely, the applicant does not even acknowledge the existence of the Wild and Scenic River Designation, checking the box for "not applicable" when disclosing impacts to protected areas—e.g., wilderness and "similar preserves." V. Failure To Acknowledge Need For Extraordinary Stormwater Control Measures The applicant states that the project will comply with local ordinances and ORW rules, but the application's brief discussion of Best Management Practices (BMP) does not show how this could possibly be true. Perhaps the applicant is thinking of the basic requirement to control 1 inch of rainfall from high-density developments in ORW watersheds. The applicable Jackson County ordinance, however, requires detention and control of a 25 -year, 24-hour storm event. According to information available from NOAH, such an event would produce between 9 and 11 inches of rain In Cashiers. The applicant's plans do not make room for the structures that would be needed to adequately manage this amount of rainfall. VI. The Applicant's Mitigation Plan Is Legally And Practically Inadequate The mitigation described in the application is utterly Inadequate. First of all, there should be much more explanation of the 1;1.5 ratio for wetlands mitigation. Wetlands contiguous to streams designated as ORW must be mitigated at a 4:1 ratio far "restoration," and even higher ratios for enhancement or preservation. 15A NCAC 02H .0506(h)(7). Second, the applicant offers no mitigation whatsoever for stream impacts. Nor, as explained above, does the applicant acknowledge what additional stream impacts would result from the "future development," much less provide mitigation for those impacts. Third, the proposed mitigation does not meet the requirement to locate mitigation in the same sub - basin unless impractical to do so. See 15A NCAC 02H .0506(h)(9). it appears, Instead, that the applicant intends to pay in -lieu fees to claim credits for wetlands restoration In a totally different basin (Tulula 4 1 P a g e Creek, which drains to the Gulf of Mexico via the Little Tennessee). No attempt is made to show how this mitigation could prevent significant degradation of the special aquatic resources that will be impacted in the Chattooga basin. Nor is there any information provided to show that it would be impractical to mitigate these impacts in the Chattooga River watershed. Indeed, based on comments submitted by Wildlife Resources Commission on June 6, 2018, it appears that there Is a practical option for mitigation in the immediate vicinity of the development. The application should be rejected on this basis alone. VII. Inadequate Information To Allow Public Input On Compliance With Outstanding Resource Water (ORW) Requirements In addition, the application does not provide enough information to inform public comment on the plans for treating human waste that will come from the proposed hotel and subdivision. The application acknowledges it will tie into the nearby sewage collection system that goes to the Cashiers Waste Water Treatment Plant (WWTP), but does not explain how this would not lead to an "expansion" of a discharge Into an ORW, which is prohibited understate law. 15A NCAC 0213.0225(c)(1). Currently the Cashiers WWTP is operating at approximately 50% of permitted flow for the plant. Even if the Cashiers WWTP has the theoretical capacity to handle the increased load, violation of National Pollutant Discharge Elimination System (NPDES) permit conditions have already occurred in the past. The applicant must show why those violations would not be more numerous or serious with the proposed increased load. VIII. The Project Cannot He Allowed To Cause Further impairment Of An ORW Further, TWSA intends to boost operations of this WWTP to 100% of its permitted flow, to service approved, realized customer allocations Including the applicant ---effectively doubling its discharge into an ORW (personal communications). While clearly initiating an "expansion" of a discharge into an ORW, the application falls to disclose how NPDES permit compliance would be achieved by operating the Cashiers WWTP at 100% of its permitted flow. Though TWSA asserts that the Cashiers WWTP has been designed to accommodate up to 400,000 gallons per day of inflow (sewer plus infiltration during a storm event), this does not account for the fact that the excess inflow is often "flash treated" with chemicals and released directly into receiving waters, which most certainly will negatively impact Outstanding Resource Waters. We have grave concerns that heretofore unused allocations will be used in a way that increases the existing discharge from the WWTP. Regardless of how much the permit allows as discharge, the actual discharge has been much Iowersince the Chattooga River was designated ORW. The regulations prohibit expansion of existing discharges, not expansions of existing permits. We doubt that it is lawful to treat slack in the WWTP permit as a property right that can be bought, hanging as a threat overthe water quality of a National Wild & Scenic River, whose water quality is supposed to be maintained or improved. 5jPage In addition, the Chattooga River in the project area (from source to the Cashiers Lake dam) is potentially impaired for aquatic life due to low dissolved oxygen (DO). Low DO is caused by impoundment (due to increased temperature, lower surface area interaction, and change in vegetation). Deepening the impoundment and removing the wetlands would exacerbate this violation, which is impermissible in an ORW. 15A NCAC 02H .0506(b)(3); 15A NCAC 0213.0201(e). Indeed, failure to address this issue highlights another defect In the application: the applicant does not explain the proposal's impacts against the "no action" baseline. Withoutthe dredging and development this lake would continue to naturalize sediment and form wetland habitats until the reservoirfills up, with the Chattooga River restored to surface flow, solving the low dissolved oxygen problem. The applicant must show how it can at least provide comparable water quality to the "no action" scenario. IX. Conclusion We request a public hearing to address the obvious inadequacies, deficiencies, failures and lack of Information in this proposed project, which include: failure to provide a no -action alternative to the potential negative impacts and degradation to the Wild & Scenic Chattooga River as outlined above; the proposal improperly segments and does not address a larger development plan; failure to address impacts to downstream values caused by inadequate measures to protect against erosion and sedimentation from land disturbing activities, and increased volume of sewage discharges; inadequate information to allow public input on compliance to protect Outstanding Resource Waters; inadequate disclosure of storm water control measures during extreme weather events; a mitigation plan that is legally and practically inadequate; and, the inevitable degradation and impairment of Outstanding Resource Waters and by association the Outstandingly Remarkable Values of the National Wild & Scenic River, which is longest and most pristine National Wild and Scenic River in the Southeastern U, S. It is essential that ACE grant a public hearing to address these obvious omissions and inadequacies, for the public to give meaningful input on this proposed project in order the protect the Chattooga River and its ORW. Sincerely, Nicole Hayler Julie Mayfield Executive Director Executive Director Chattooga Conservancy Mountain True 61Page Board of Directors Bill Mnaldin, President John Maas; Vier President Karen Patterson. Secretary Amy Pattersoq Treasurer Sandy sarrmv Bob Bryan Ghee cogmvell Shama lona Cola Lawrence Dbnnitt Carlton [ting Kathie marsh Richard Melvin Hfllrie Qnin Tara Tracy walter Wingud JeffZahaer sulf Eroeoatfve Director Gary Weia, PhD Development Director Julie Schon stewardship Coerdiaator Kyle Pursel EdacaGon Ceardmalor Samb Parcel June 08, 2018 -c".1erv: D TRUST Places since 1949" Mr. David Brown USACE Wilmington District — Asheville Regulatory Field Office 151 Patton Avenue, Room 208 Asheville, North Carolina, 28801-5006 Dear Mr. Brown: imrP9TirMr� kdUN U 8 1018 19T .............. The comments below relate to an application submitted by the Cashiers Canoe Club Development, LLC (Corps Action ID Number: SAW -2016-00032). The mitigation of lost wetland in basin is preferred over the mitigation out of basin. It is not clear from the public notice where the required mitigation will take place. It is our concern that NC Division of Mitigation Services (DMS) will use the resources for mitigation from this project out of basin. My Land Trust is aware of a Southern Appalachian Bog within the Tugaloo Basin that is available for both restoration and preservation. This site is Iocated within Horse Cove and has been identified by the USFWS as part of the Blackrock CPA. The land owner is interested in selling this property if it is conserved. The site is home to a population of purple mountain pitcher plants (Saracenia purperea var montana) and is recognized as a North Carolina Natural Heritage Area (Horse Cove Bog). HCLT would be interested in aiding in this mitigation endeavor. It would be a significant impact to the Chattooga River if it was used to handle the waste water discharge from any treatment facilities associated with this large development. The Chattooga is a Wild and Scenic River and should remain so, Thank you for your attention to this matter and if you have any question regarding my comments please do not hesitate to contact me at hitrust earthlink.net or 828-526-1111. Yours in conservation, i 7� Gary R. Wein, Ph.D. Executive Director 348 South 51h Street- PO Box 1703 • Highlands, NC 28741 828.526.1111 a hitrusi@eartlilh"ct a www.hicashit.org CASHIERS AREA CHAMBER OF COMMERCE (OMNumm k WNNm m w mlkhtr= Serving the Communities of Cashiers, Glenville, Sapphire & Lake Toomway June 6, 2018 Mr. David Brown USACE Wilmington District —Asheville Regulatory Field Office�J�� ZQ�� 151 Patton Avenue, Room 208 PL Asheville, North Carolina, 28801-5006 Re: Corps Action ID Number: SAW -2016-00032 Dear Mr. Brown: On behalf of the Cashiers Area Chamber Board of Directors, I write to express our organization's endorsement of the application of Roseanne Giordani of Cashiers Canoe Club Development, LLC (Cashiers Canoe Club) for the authorization of environmental improvements associated with the Cashiers Lake Dredge and Development Project in Cashiers, Jackson County, North Carolina. It is our opinion that this proposed activity is wholly in the public's interest as the lake has deteriorated over the decades and inhibited aquatic sustainability, responsible economic growth and recreational enjoyment in its vicinity. This permit will allow for significant improvement and mitigation of the current adverse conditions with full consideration and safeguarding of the environment. This project also will significantly benefit the $190 million per year tourism industry in this rural Western North Carolina county and is consistent with a regional hospitality strategy to expand accommodation options while enhancing and featuring natural assets in the area. We urge a favorable assessment in the forthcoming Environmental Impact Statement (EIS) pursuant to the National Environmental Policy Act. Thank you for the opportunity to comment. Sin erel , Debby Hatt , President Copy to: Applicant: Ms. Roseanne Giordani Cashiers Canoe Club Development, LLC P.O. Box 300849 Austin, Texas 78703 Agent: Mr. Clement Riddle ClearWater Environmental Consultants, Inc. 32 Clayton Street Asheville, North Carolina 28801 202 U.S. Highway 64 West / Post Office Box 238, Cashiers, North Carolina 28717 828.743.5191 info@CashiersAreaChamber.corn Craig PendaWnt 646 Wflson Road Adwts, Georgia 34318 cpenduVast@taylor=4hI =m June 8, 2018 By Eman David Brown U.S. Army Cmps ofEnginem Wilmington Dishict — Asheville Regulatory Field Orae 1.51 Patton Avenue, Room 208 Asheville, NC 28801-5006 Davjd,W.Brom9ftwe.g= Karen Higgins North Carolina Depuftnent of Water Resaurnes 512 N. Salisbury St, 91h Floor Raleigh, NC 27604 bren.hi Rc: Public Comment Corps Action LD.: SAW -2016-00032 Cashiers Canoe Club Dervelopnm% LLC Cashiers Lake Dredge and Fill permit Application Upper Chattooga River Watershed Dear Sirs; R- 'W,- 'JUNO 8 2018 BY:................. I am a long time owner.of property in South Tackson County in Whiteside Cove in the Chattooga River watershed. I an very familiar' with the Upper Chattooga watershed and use it fmquently for rectutional purposes. I know the area in and around Cashiers Lake well, too. Over the years, I have noted it dpificaut degradation of water quality with excessive station and trntbidity of the Upper Chattooga including its tributaries. As an OwUmding National Reso = Water, it must be protected from any ft0 er de edatlon. I am deeply concerned about the proposal to dredge Cashiers Lake, fill portions of its 4a ant wetlands, and install bulkheads around portions of its perimeter. My biggest conc;= arises $om the likelihood that the dredge and fill operations cant be, conducted in a manner which avmde release of turbid, muddy water into the Gaga Diver downst mm; of Casbun Lake. BEFORE any Sectkm 404 dredge and fill permit or Section 401 water quality raa fication could properly be considered or potmfu&Uy issued with respect to the proposed project and appfication, it is vital that detailed plans be presented that reflect all measures to be taken to avoid any surd releases under all potential conditions, including high rainfall conditions. I do not believe gab detailed plane have been pmesentod to data, Accordingly, bdm any fisrther comai8wdm is given.te the Applicant in queo fbr Issuance of a Sectim 404 permit or Sectkm 401 water quality man, mgmficant . additional detailed iafinmation of a lsi *-cx edrble nature mast be requiredfrom fie Applicaut-and must be subject to cared sir. Among other tbmgs, me or more public hearings shmdci be held, and an opportunity for the public to ask and receive detailed auewere from the Applicont and ib consultant should be In any evcnts the Application appears to be veay F=aWm since it is part and parcel of a larger develapmmt play but the Applicant aclmowledges that such &&bpm ent plen is still hL its conceptual stage- The entito drMop ment plan, including doWle rgaft pm ftdve me mmo., storm water management, unavoidable and wftftdedcoencoo, mon measnras, and a W assessment of altomativae, must be prorated befre fnli and proper cxmsidcvWon and wd m Mm be talon by your agencies and. cmnsuithig Agemles on a rggcurstod Sectin 404 permit and. Section 401 certification. To: David Brown JUN 1 12018 Army Corps of Engineers r �� Re: Proposed development on Cashiers Lake in Jackson County W Dear Mr. Brown, As residents of Jackson County and as people very concerned about maintaining the beauty and health of the environment in this area, we are writing to express our serious issues with the proposed development on Cashiers Lake. First, the lake sits at the headwaters of the Cbattooga River which is designated a Wild and Scenic River which we know requires special protective measures. It is hard to imagine how dredging of the scale proposed would not result in a bolus of sediment and other material flowing directly into the river and causing permanent damage to the river as we know it. This has not only ecological impact but also commercial impact on small companies who lead fishing, rafting and recreational opportunities on the river. Second, we seriously question the wisdom of destroying over 6 acres of wetlands. It is our undcrstmding that the 3vetland area has matured for almost 100 years (lake construction 1920). The proposed project will eliminate the biofiltration of this mature area thus stressing water quality and increasing the flooding problems that already exist around the iakc area. In addition, the footprint irali rvd far SS hmTs€:s, hots} airs, amenities will put further stress on the hydrology of this area even without allowing wetland disruption. We think that it is imperative that there be a forum for residents to hear details and plans before such a major project is undertaken. No one heard about this until this week. We know nothing about remediation plans, impact studies, etc. We dm't know that the developer is willing to do the clearly needed remediation. We mrn't necessarily against any development but it should not be done at the expense of our bti utiful environaent for the sake of a fear new folks and the pocket book of -the developer. Looking forward to seeing a meeting planned in the near future. Leah and Bill Horton PO Box 2123 Cashiers, NC 28717 828-743-7486 Dargan, Mary Palmer <mpdargan@dargan.com> DO YOU HAVE AN EMAIL ADDRESS FOR THEM??? 6 messages Dargan, Mary Palmer <mpdargan@dargan.com> To: "Turner Insooe (turner@turnerinseoe.com)" <turner@tumerinscoe.com> Issue Date: May 9, 2018 Comment Deadline: Jane 8, 2018 Corps Action ID Number: SAW -2016-00032 Mr, David Brown USACE Wilmington District — Asheville Regulatory Field Office 01 Patton Avenue, Room 208 Asheville, North Carolina, 28801-5006 Dear Mr. Brown, Thu, Jun 7, 2018 at 5:49 PM n TITS` tJUN 120i8 I am a direct neighbor of Cashiers Lake in Cashiers NC, the. subject of this review. The lake in questions is in terrible need of dredging. It is so shallow that it backs up water on the main road : Frank Allen Road is at the top of the lake. Cashiers Canoe Club is doing a great service to the community by dredging this lake. It has long been an eyesore and a big problem for the community. Everyone drives down that roadl Please approve this permit. 1 speak on behalf on many, many people who are scared to cross the road when if is flooded to simply get to the post office or the library. Sincerely, Mary Palmer Dargan 35 Flash Point Drive Cashiers, NC 28717 Mary Palmer Dargan, Lkznsed LandswPe Architect (PLA) 404-354r1715 (c), 828-743-0307 (0) PODGAST swrwsI ') ix aeless Landscape Desi x NEW BOOK: Lifelong Landscape Design Z1 0 f 60 Celebrating Dargan Landscape Architects 44th year of Serving. Heal The Earth One Garden at a Time. Brown, David W CIV USARMY CESAW (US) From: Wallace, Nancy L CIV USARMY CESAW (US) Sent: Thursday, May 10, 2018 10:39 AM To: Marsh Smith Cc: Brown, David W CIV USARMY CESAW (US) Subject: RE: US Army Corps of Engineers Wilmington District Public Notice - Marsh Smith Mr. Marsh, Thank you for your email. I have forwarded your response to Mr. David Brown, Regulatory Specialist, for this project. Nancy . --Original Message --- From: Marsh Smith[mailto:marsh@marshsmithlaw.com] Sent: Thursday, May 10, 2018 9:13 AM To: Wallace, Nancy L CIV USARMY CESAW (US) <Nancy.Wallace@usace.army.mib Subject: [Non-DoD Source] RE: US Army Corps of Engineers Wilmington District Public Notice "6.96 acres (ac) of permanent wetland impacts (fill and dredging)" is way too much.... Should be nothing at all for an outfit with the name "Cashiers Canoe Club". Marsh Smith Law Office of Marsh Smith, P.A. P.O, Box 1075 Southern Pines, NC 28388-1075 910-695.0800 office 910-215-6629 cell From: Wallace, Nancy L CIV USARMY CESAW (US)[mailto:Nancy.Wallace@usace.army.mil] Sent: Thursday, May 10, 2018 8.03 AM Subject: US Army Corps of Engineers Wilmington District Public Notice As you requested, you are hereby notified that Wilmington District, United States Army Corps of Engineers has issued a Public Notice. The text of this document can be found on the Public Notices portion of the Regulatory Division Home Brown, David W CIV USARMY CESAW (US) From: Chattooga Conservancy <info@ chattoogariver.org > Sent: Monday, lune 4, 2018 2:25 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non -DOD Source] NC DMS letter David, Please provide us with the NC DMS letter dated Jan. 12th. Also, I see nothing in the Cashier's Lake Project site plan of other Corp material that addresses the impact of a sewer line for such a large project that ties directly to a wastewater treatment plant that is already capped at 200k for the Chattooga River and which is operating at a maximum. Buzz Williams, Chattooga Conservancy Chattooga Conservancy info@chattoogariver.org <mailto:info@chattoogariver.org> 9 Sequoia Hills Lane Clayton, GA 30525 tel. 706.782.6097 Blockedwww.chattoogariver.org <Blockedhttp://www.chattoogariver.org> Brown, David VII CIV USARMY CIErSAW (US) From: Chattooga Conservancy <info@chattoogariver.org> Sent Monday, June 4, 2018 7:59 AM 7b: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Public hearing request I am writing to request a public hearing regarding the proposed development on Cashiers Lake in Cashiers N. C. to explore concerns for the possible impact to the water quality and aquatic ecosystems in the Chattooga National Wild and Scenic River related to ground disturbing activity, wetland dredging and stream disturbance. Buzz Williams, Chattooga Conservancy Chattooga Conservancy info@chattoogariver.org <maiito:info @chattoogarive r.org> 9 Sequoia Hills Lane Clayton, GA 30525 tel. 706.782.6097 Blockedwww.chattoogariver. org<Blockedhttp://www.chattoogariver.org> '64+.LLd Me. tt ori Brown, David W CIV USARMY CESAW (US) From: Barrett Barker 4 b barker@ clemson.edu >. Sent: Wednesday, June 6, 2018 10:21 AM lir To: Brown, David W CIV USARMY CESAW (US) Subject: [Non -Dob Source] Public hearing P�! 2018 Kind sir, I am writing to appeal to you to call fora public hearing regarding the Texas developer who has applied for a permit from the U.S. Army Corps of Engineers to dredge Cashiers Lake in the headwaters of the Chattooga River as part of a plan to build a 100 -unit resort hotel and a 55 home residential community. Dredging almost 18 acres of lake bottom will destroy 6.54 acres of wetland. Ground disturbing activity for the development will also impact aquatic life in feeder streams. The project plan does not provide adequate information regarding storm water protection safeguards in case of excessive rainfall common to the headwaters. A sewer line for this high density development will stress the wastewater treatment plant on the Chattooga River that has been capped at 200 thousand gallons a day to protect the river that is classified as Outstanding Resource Waters. live in Oconee county, SC and use the Chattooga for recreation and personal wellbeing. My family cherishes the natural beauty and pristine experiences provided by the river, and I believe maintaining the current natural state without degradation of the water quality upstream is paramount to keeping the Chattooga wild and scenic. Please do your duty and provide the citizens the ability to have a voice in the proposed development above the headwaters. Thank you. Barrett Barker CLEMSON UNIVERSITY Department of Physics and Astronomy Physics and Astronomy Research Lab bbarker@ciemson.edu <mailto:rasimp@clemson.edu> 864-656-5311 Brown, David W CIV USARMY CESAW (US) From: Gina Goldkuhl <rgoldkuhl3@gmall.com> TM Sens: Wednesday, lune 6, 2018 10:13 AM 'JUN � s ���� To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Requesting a Public Hearing David Brown, The proposed development near the headwaters of the Chattooga River must be considered with great concern to the local community and environment. Dredging nearly 18 acres of Cashiers lake compromises the precious wetland habitat - some of the most sensitive and already dwindling ecosystems in the US. Building a hotel AND residential community will strain the infrastructure at the watertreatment plant. As a community stakeholder, paddler, and clean water enthusiast, I urge you to take our voices into account. Listen to our concerns and take the course that represents ALL parties' wishes. Thank you! Regina Goldkuhl Brown, David W CIV USARMY CESAW (US) From: Chip Sanders <chipsanders89@gmail.com> Sent Wednesday, June 6, 2018 9:54 AM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Cashiers Lake Dredge & Proposed Development Mr. Brown, I have recently learned of the planned dredging and subsequent development of Cashiers Lake. I work and live on the Chattooga River that is fed by this lake and am greatly concerned about the water quality issues that this plan might create. For my safety and that of my guests, I urge you to call a public hearing where I can voice my concerns to you, the developers, and the rest of the interested public. This river belongs to all Americans and we have a right to know exactly how it is being threatened before any decision can be made. Thank you for your consideration. Chip Sanders Section III Trip Leader Southeastern Expeditions Clayton GA 'JUN Q 6 2O)8 Brown, David W CIV USARMY CESAW (US) From: Adam Mobley <amobley1108@gmail.com> Sent: Wednesday, June 6, 2014 9:52 AM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Cashiers Lake Dredging `JUN 0 6 2w Hello, My name is Adam and I am a whitewater kayaker and frequent visitor of our wild spaces. I recently learned of a developer who has applied for a permit to dredge Cashiers Lake in.preparation for a new high density development which appears to threaten one of these pristine places. It is my understanding that the project'plan lacks adequate information around stormwater management. Also, I am concerned that the sewer line will stress the wastewater treatment plant on the Chattooga River that has been capped at 200,000 gallons a day to protect the river that is classified as Outstanding Resource Waters and has been designated as a Wild and Scenic River. I have additional concerns that this dredging operation could negatively impact upwards 6.54 acres of wetland in the area. As I am sure you are aware by now, I am not alone in my concerns, so I humbly request that a public hearing be convened as soon as possible to address these concerns prior to the permit being issued. Thanks, Adam Mobley Brown, David W CIV USARMY CESAW (US) From: Christine Nadine <christinenadine@ymail.com> 4M Sent: Wednesday, June 6, 2018 8:58 AM P AM P 6 1018 To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Cashiers Lake - request public hearing Dear Sir, I am greatly concerned to learn of the developer who has applied for a permit to dredge Cashiers Lake - headwaters of the Chattooga Wild & Scenic River, to build a 100 unit resort. This project will have a significant impact on the aquatic environment and all associated wildlife. I request that you hold a public hearing so that we can both learn more and also voice concerns. Thank you Christine Nadine Sylva, NC Brown, David W CIV USARMY CESAW (US) From: Starr Silvis <starresilvis@yahoo.com> Sent: Wednesday, June 6, 201 S 9:00 AM To: Brown, David W CIV USARMY CESAW (US) pink6 2D)8 Subject: [Non-DoD Source] Chattooga River Dear Mr. Brown, am writing to request a public hearing for the proposed development on the Chattooga River Headwaters. The application is for dredging of Cashiers lake. The impacts of.this proposed action are far reaching and in direct opposition to the protections intended by Nationals wild and Scenic designation. I am a water resources engineer who was in charge of NCDENR 401 certifications in the ARO for several years. The area where this project is proposed is one of the highest rainfall areas in the US. It is also an Outstanding Resource water. There must be special measures taken to assure stormwater management for frequent and heavy rains. This includes any dredging activities and development activities. I have worked with many projects in that area and all have had problems related to lack of understanding and proper preparation and planning for the frequent and heavy rainfalls experiences in that area. Furthermore, dredging will impact over 6 acres of headwater wetlands which are Integral to to health of the Chattooga River. Please Feel free to contact me with any questions and put me on the contact list for any public information regards if activities in that watershed. Sincerely, Starr Silvis, MS PE Brown, David W CIV USARMY CESAW (US) From: NANCY T JAMES <ntjames@clemson_edu> iv Sent Wednesday, June 6, 2098 8:05 AM To: Brown, David W CIV USARMY CESAW (US) JUN 0 6 1018 Subject: [Non-DoD Source] Public Hearing I would like to request a public hearing to discuss the potential threat to our National Wild and Scenic River. I've heard that a permit has been applied for to dredge Cashiers Lake as part of a plan to build a residential community. More information is needed and a discussion is warranted based on the damage to the wetlands, the danger to the aquatic life, the strain this could cause on the wastewater treatment plant, among other things. Thank you for your consideration. Nancy T. James '89 Research Analyst Brown. David -W CIV USARMY CESAW (US) From: Nick Terry <pnterry382@gmail.com> Sent: Wednesday, June 6, 2018 11:59 AM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non -Dol) Source] Request for a public hearing - hsMke Development and risen Dredging -Nick Terry [�. irl 'JUN 0 6 2018 ju Mr. Brown, would like to request a public hearing on the proposed plan to dredge Lake Cashiers to support a resort and residential development. Lake Cashiers is an important feeder of the Chattooga River headwaters, and dredging the lake would impact the oldest federally designated Wild and Scenic river in the United States. In addition, I have concerns regarding the planned use of the Cashiers wastewater treatment plant to support the development. Relying on the Cashiers plant for this development would negatively impact the water quality of the Chattooga River, an important source of tourism and economic benefit for many communities downstream. Protecting the Chattooga River and its headwaters is important to many surrounding communities. Please take the above into consideration, and push for a public hearing on the matter. Thank you for your time. Nick Terry 770 826 0699 Brown, David W CIV USARMY CESAW (US) From: Chad and Ashby Garner <rolfinethodsi@gmail.com> Sent: Wednesday, June 6, 2018 11:58 AM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Public Hearing Request: Cashie's�d Dredge Chad & Ashby Garner - t1 6 701$ �' Hello Mr. Brown, As a Jackson County landowner and business owner in the area I am requesting a public hearing based on the proposed new development of resort and residences on Cashiers Lake in Cashiers, NC. We need to closely examine the potential negligent impact on the wetlands and feeder streams into the pristine and protected Chattooga River. I look forward to this hearing. Regards, Ashby Underwood Ashby Underwood -Garner Chad Garner Practitioners of Structural Integration The Ida P. Rolf Method 828-526-8880 Blockedwww.rolfinethodsi.com <Blockedhttp://www.rolfinethodsi.com> Brown, David W CIV USARMY CESAW (US) From: Chevin Woodruff <chevin@splendormountain.com> Sent: Wednesday, June 6, 2018 10:28 AM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Beauty of Chattooga River Hearing - Chevin Woodruff Pt"T�W- - — Good morning, f JUN 0 6 2018 My grandfather was James Waldo Woodruff,Sr., there is a dam named for him. He was nicknamed Mr. Chattahoochee. I would very much like to attend a hearing before a man who is seeking wealth at the expense of a natural beauty such as the river 20 minutes from my home in Tiger, GA, it is my opinion that a few acres can do a body good and that these neighborhoods which cause more envy than not are not the best way to live life. Go to the country, Do your part to help maintain the country to go to. It's rewarding indeed. Think of a memory, was it in the forest, a lake and farm? Please have a hearing. We don't want this disruption to a river and the inhabitants. My warmest regards, Chevin Chevin Woodruff, President Blockedwww.SplendorMountain.com<Blockedhttp://www.SPiendorMountain.com> 404.27.8.7638 Brown, David W CIV USARMY CESAW (US) s--%- From: Derek Enderlin <derek@rossenderlin.com>!'' Sent: Wednesday, June 6, 2018 11:14 AM ' To: Brown, David W CIV USARMY CESAW (US) r VlB J# f�E An �r Subject: [Non-DoD Source] Cashiers Lake - Derek Enderlin I understand there Is a possibility that Cahiers Lake may be dredged. l would like for there to be a public hearing if this is considered as it could have significant impact on the environment. Thank you for your kind attention to this matter. Derek J. Enderlin Ross and Enderlin, PA 330 East Coffee Street Greenville, SC 29501 854.647-7205 Fax: (888) 850-3522 Brown, David W CIV USARMY CESAW (US) From: Sam Cleary <clearysam96@gmail.com>a Sent: Wednesday, June 6, 2018 11:12 AM To: Brown, David W CIV USARMY CESAW (US)f0 Subject: [Non-D.oD Source] Cashiers Lake - Sam Cleary David, I'm emailing you as someone that cares greatly about the protection of our watersheds, and natural environment. I'm requesting a public hearing concerning a developer applying for a permit to dredge Cashiers lake, and to build a resort hotel and residential community. This would be a tragedy for the area. This would do long term damage to the Chattooga River headwaters, as well as damaging wetlands, and putting an increased stress on the Cashiers wastewater treatment plant, which is already at capacity. A public hearing would allow all sides to comment and give input into this development, which I believe would show how much people care about this area, and don't want to see it damaged by more needless development. I can guarantee that if such a bearing were to occur, i would,be present in opposition to this permit being granted. Thanks you for your time, Sam Cleary Brown, David W CIV USARMY CESAW (US) From: Jacob Cooper <jdcooper@uga.edu> Sent: Wednesday, June 6, 2018 12:21 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source) Public Hearing Request - Cashie J% i%%ftdla lopment - Jacob Cooper `�f Hi David, I would like to voice my concerns and add a request for a public hearing about the non -extensive nature of stormwater management plans for the proposed dredging and development on Cashiers Lake, which could potentially affect the water quality of the Chattooga River and numerous tributaries both upstream and downstream of the lake. Another major concern is the feeding of sewer lines from the development into the Cashiers wastewater facility, which is already running at maximum capacity for the purpose of protecting the river. The Chattooga is a National Wild and Scenic River, as I'm sure you know, and is an invaluable resource for thousands of people. It is worth protecting in as many ways as possible. Thank you for your time. Respectfully, Jacob Cooper Environmental Economics and Management UGA 2018 jdcooper@uga.edu <mailto:jdcooper@uga.edu> Personal and/or Business Inquiries: jcoopermedia@gmail.com <mailto:jcoopermedia@gmail.com> Brown, David W CIV USARMY CESAW (US) From: Charles Huyck <cdhuyck@hotmaii.com> Sent: Wednesday, June 6, 2018 12:21 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Request - Chuck Huyck Po� Me and many other request a public hearing discussing intents to dredge cashiers lake for development. This can serverely impact headwaters of the wild and scenic chattooga river. American whitewater has been notified. Thankyou. Sent from my Samsung Galaxy smartphone. Brown, David W CIV USARMY CESAW (US) From: T Ray atimskrbelieve@aol.com>tim Sent: Wednesday, June 6, 2018 9.34 AM To: Brown, David W CIV USARMY CESAW (US) 0 6 Cc: timskrbelieve@aol.com Subject: [Nan-DoD Source] Project at Cashiers- T Ray Mr. Brawn, I would request that there be a public hearing on the project to dredge a lake near Cashiers and develop houses. I am concerned the project has not provided enough information on now it will deal with stormwater: lam also concerned with the impact of more wastewater on the sewer plant I regard to its discharge into the Chattooga river headwaters. Thank you. Tim Ray 170 Hidden Valley Drive. Montevallo, AL. 35115. timskrbelieve@aol.com P, TM rM C--- — - - — --- UN Lfl 2018 Brown. David W CIV USARMY CESAW (US) J From: Seth Ammons <ammonssw1998@gmail.com> Sent•Wednesday, June 6, 2018 2:04 PM To: Brown, David W CIV USARMY CESAW (US) Subject•. [Non-DoD Source] REQUEST FOR PUBLIC HEARING ON CASHIERS LAKE DEVELOPMENT - Seth Ammons JUST GOT WORD ABOUT THE PROPOSED CASHIERS LAKE DEVELOPMENT THAT WILL DESTROY WETLANDS AND HAS THE POTENTIAL TO DESTROY THE CHATTOOGA RIVER AND FLOOD SURROUNDING AREAS. ALSO I HAVE BEEN TOLD THAT IT WILL VIOLATE PARAMETERS ALREADY IN PLACE TO PROTECT THE CHATTOOGA RIVER ATTHE CASHIERS WASTE WATER TREATMENT PLANT. PLEASE CALLA PUBLIC HEARING ON THIS PROPOSED DEVELOPMENT. REGARDS, SETH AMMONS /M rflq^ rp- 9M Brown. David W CIV USARMY CESAW (US) ' From: Erica Ammons <eammons1 @msn.com> Sent•Wednesday, June 6, 2018 2:04 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Chattooga river Worries at Cashier's lake development - Edca Ammons I request a public hearing in order to learn more info in the proposed development of Cashiers lake of the chattooga river area that will destroy the chattooga river and the wetlands around the Cashiers Lake. I have heard the Cashiers waste water treatment is not equipped to handle the additional burden. Please contact me at my email or feel free to text to 865-388-7093 Erica Ammons Brown, David W CIV USARMY CESAW (US) From: Taylor Parrish <tcparris2@gma1l.com> Sent: Wednesday, June 6, 2018 9:36 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Re: Protect our land Public Hearing on Proposed Permit for potentially harmful development - Taylor Parrish In Clarification for Mr. Brown, The aforementioned statements are in reference to requesting a public hearing be granted to discuss these important Issues. Sent from my iPhone > On Jun 6, 2018, at 9:28 PM, Taylor Parrish <tcparris2@gmall.com> wrote: > Dear Mr. Brown, > As citizens of WNC, Tristate, and surrounding counties of the Chatooga river and surrounding biodiversity and freshwater resources, we deserve to have a say in any externalities that could manifest as a result of the dredging of Cashiers lake. Any development in this area not only posses threat to our natural resources but of the integrity and stability of our economy. The potential harm is twofold. One on the destruction of our scenic driven tourist economy, and two, on the harm to our environment. in this area our environmental laws and economic models go hand in hand. A large development that could potentially overwhelm the water reservoirs and ecological sustainability would ultimately drive economic depression, > Please consider the rights we as citizens have to voice our concerns on any externalities and hence threats to our livelihoods and development as a region. I was born, raised and still live in Highlands NC. This area holds my spirit and any large development should carry with it a harmonious relationship with the beauty and nourishment this land and resources provide. > Development requires care for and close consideration of our limited resources, otherwise it's destruction of the many for the benefit of the few. This model is not sustainable, and may work in the short term, but will ultimately lead to the destruction of our beautiful home. > Please show that you care forthe past, present, and future lives of the citizens before permitting any development that will bring harm to our water systems and ecological uniqueness. > > Taylor Parrish > Nursing Student @ SouthwesternCC > BA International Studies > NC Resident and Citizen > Tcparris2@gmail.com > 828-200-9306 > > Sent from my (Phone Brown, David W CIV USARMY CESAW (US) From: Chanda Morrison <chandamorrison@gmail.com> TM er"i ,.R r, Sent: Wednesday, June 6, 2018 1:23 PM To: Brown, David W CIV USARMYCESAW (US) `JUS Subject: [Non-DoD Source] Public Hearing Request - Chad MorrisonPC! }$ Mr. Brown, I request that a public hearing be held regarding the permit application for dredging Cashiers lake. I am concerned for several reasons and worry that the proposed sewer line would go to the Cashiers wastewater treatment plant which is already maxed out for what it can handle on a daily basis. 1 want to learn more about this potential threat to the Chattooga River watershed. Thank you for your consideration, Chanda Morrison Brown, David W CIV USARMY CESAW (US) From: Mark Roy <outdoorsforme2014@gmail.com> VM Sent: Wednesday, lune 5, 201 S 12:29 PM Pit" To: Brown, David W CIV USARMY CESAW (US) 'JUS! 0 8 1018 Subject: [Non -Dol) Source] Cashiers Project - Mark Roy Dear Mr. Brown, I request that you hold a public hearing to get more information about the project near Casiers, NC to drain a lake. I am concerned this will affect wetlands, put a heavy load on the wastewater treatment plant and eventually affect the headwaters of the Chattooga river. Thank you Michael Roy Birmingham, AL Brown. David W CIV USARMY CESAW (US) From: Rachel Kinback <raekinback@gmail.com> Sent: Wednesday, June 6, 2018 12:13 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Please schedule a Public H WWE44N ;O o dredge Cashiers Lake - Rachel Kinback TJVN D 6 1018 j Dear Mr. David Brown, I am writing in hopes that you might please schedule a Public Hearing regarding the plan to dredge Cashiers Lake. I have recently heard that a developer has applied for a permit to dredge Cashiers Lake. Cashiers Lake feeds the headwaters of the Chattooga River, which is an area I hope we can all come together to protect. Dredging here could have major effects on the River's headwaters during heavy rainfall. The wetlands surrounding Cashiers Lake are an important buffer in these situations. I am also concerned about the sewer line(s) and system for the proposed development and feel it is my right to be presented with more information before this plan can move forward. I look forward to the opportunity to learning more about this proposed project at a public hearing. Warmly, Rachel Kinback YogaHighlands.com <BIackedhttps://docs.google.com/uc?id=OBwOrsgv8XiimYWpwei1USWZUQVU&export=download> Brown, David W CIV USARMY CESAW (US) From: Matt Nielson <mattfisher22@gmail.com> Sent: Wednesday, June 6, 2018 11:55 AM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Public hearing for proposed development in Chattooga Headwaters - Matt Nielson David, I'd like to request a public hearing on the proposed development and likely accompanying actions for the Chattooga River Headwaters and tributaries. The Chattooga is an amazing resource, a Wild and Scenic River, and a recreation hot spot for many. Any development that would impact this watershed deserves careful review and public discussion. Would you be willing to consider a public hearing? Respectfully, Matt Nielson Matt Nielson 706-534-4216 Please note my new #1 n TM OKI rnr V? }� Brown, David W CIV USARMY CESAW (US) no From: Dan Pittillo <dpittillo@gmail.com> oc, Sent: Thursday, June 7, 2018 6:31 AM To: Brown, David W CIV USARMY CESAW (US) "JUN 0 7 2018 Subject: [Non-DoD Source] Dredging Cashiers Lake proposal Dear Mr. Brown: As a part of the headwaters of the Chattooga Wild and Scenic Riverthe negative impact will be significant. Siltation and pollution will be significant. Secondly, the wetlands will also be affected by drainage. And the plan to add to the sewage from an additiona[ hotel or increase in population here will not be properly managed due to the excess to the sewage processing. Therefore it is not wise to approve this development project and I oppose it. Sincerely, I Dan Pittillo 601 Cane Creek Road Sylva, NC 28779 ph. 828-293-9661 or 828-226-3091(c) Brown, David W CIV USARMY CIESAW (US) io om From: Sue Harrison <suepharmon@gmail.com> r Sent: Thursday, June 7, 2018 4:43 AM f JuN 0 7 2018 To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Public Hearing requested - Sue Harmon Mr. Brown, I understand that a permit has been requested to dredge Cashiers Lake in order to make way for a large development. The impacts of such major disturbance in a wetland that feeds the Wild and Scenic Chattooga River should be carefully considered and therefore brought before the public. Please give our citizens a chance to hear about this proposal and make comments in full at a public hearing. Sue Harmon Oakwood, GA 30566 suepharmon@gmail.com <mailto:suepharmon@gmall.com> Brown, David W CIV USARMY CESAW (US) From: Melissa Welborn <mwelbom1976@gmail.com> Sent: Thursday, June 7, 2018 1:44 AM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Request for Public Hearing - Melissa Irorrr' "^< li 'JUN 0 Me. Brown, I am requesting a public hearing to learn more about the impact on Chatooga River and other feeder stream that could be caused by this development being proposed at Cashiers Lake. Thanks, Melissa Welborn Sent from my iPhone QUN 0 7 2018 Brown, David W CIV USARMY CESAW (US) From: Kim Kuchon <kimkuchon@gmail.com> Sent: Wednesday, June 6, 2018 10:17 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Chattooga river development proposal _ Kimberly Kuchon To whom it may concern, The citizens of the counties surrounding the Cherished and protected wild and scenic Chattooga river demand a public hearing on the proposal for any development that may have consequences for the integrity of the environmental health of this river. There is too little known about the proposed development at this point. Dredging cashiers Lake and destroying wetlands is a huge environmental Mistake and needs to be thoroughly evaluated before any decisions can be made. Extremely concerned citizens, Kimberly Kuchon and David Zietlow Brown, David W CIV USARMY CESAW (US) From: Charlie Mize <charles.mize@duke.edua Sent: Wednesday, June 6, 2018 9:03 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non -Dob Source] There should be a public hearing regarding the proposed Cashiers Lake dredging - Charlie Mize, ri l 'iUN 0 6 2018 Ni Mr. Brown, am writing to request a public hearing regarding the permit which has been applied for to dredge Cashiers Lake. The dredging would destroy 654 acres of wetland in the headwaters of the longest and most pristine National Wild and Scenic River in the Southeastern US. The plan does not provide adequate information about safeguards for heavy rainfall, and the sewer line for the whole development would put the Cashiers wastewater treatment plant over its capacity. Since the river is such a valuable resource, there should be a public hearing in which people can voice any concerns over Its protection or lack thereof. Sincerely, Charlie Mize Master of Env. Mgmt & Master of Forestry Candidate 2019 Nicholas School of the Environment I Duke University charles.mize@duke.edu 1336-524-3277 Brown, David W CIV USARMY CESAW (US) From: Ed Tate <stilestatel @gmail.com> Sent: Wednesday, June 6, 2018 8:41 PM f To: Brown, David W CIV USARMY CESAW (US) Subject: [loon-DoD Source] Public hearing for the dredging of Cashiers Lake -Stiles Tate Dear Mr. Brown, I am writing to request that you allow for a public meeting in reference to the proposed project to dredge Cashiers Lake ahead of a possible resort hotel. This concerns me for several reasons which Include: the destruction of more than six acres of wetland, the disturbance of 18 acres of lake bottom, the environmental impact that might come to many feeder streams, and inadequate information about stormwater protection safeguards. I ask that you allow the public to have their voice heard, and allow them to fully understand the impact this will have on our rivers and streams. We are passionate about our pristine stretch of the Chattooga river and it's headwaters. All the best, Stiles Tate David W CIV USARMY CESAW i �r,Asasrctn� FJUN U B 1818 From: Ken Voyles <kvoyles1 @gmail.com> $Y� .... Sent: Wednesday, June 6, 2018 8:28 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non -Doli Source] Cashiers Lake NC Permit Application - Ken Voyles Hello Mr. Brown. 1 am writing with concern about a permit application to dredge Cashiers Lake, which feeds the headwaters of the Chattooga River. My understanding is that the dredging will affect almost 18 acres of lake bottom and several acres of wetlands. My concern is that the project plans do not provide adequate Information about storm water protection in the event of excessive rainfall, and as we have recently received record amount of rainfall in western North Carolina, this is of significant and legitimate concern. 1 also understand the proposed sewer line for this high density development would discharge to the Cashiers wastewater treatment plant. As this facility discharges effluent to the Chattooga River and is currently near or at peak capacity, I believe additional information is necessary to protect the Chattooga River, which Is classified as "Outstanding Resource Waters". I respectfully request a public hearing so citizens can understand more fully the potential impacts of this activity. Please keep me informed of your intentions to provide such hearings. Regards - Ken Voyles Brown, David W CIV USARMY CESAW (US) From: Kathy Edwards <kathye@clemson.edu> Sent: Wednesday, June 6, 2018 4:59 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Request for public hearing on development plans for Cashiers Lake area. - Kathy Edwards PP T= AM in 0 to nn Dear sir, At 'JUN 0 6 2018 I have just learned that a Texas developer has applied for a permit from the U.S. Army Corps of Engineers to dredge Cashiers Lake as part of a plan to build a 100 -unit resort hotel and a 55 -home residential community there. Cashiers Lake feeds into the headwaters of the Chattooga River, the longest and most pristine National Wild and Scenic River in the Southeastern U. S. I am writing to request a public hearing on this permit application and its consequences. This developer's plan includes dredging almost 18 acres of lake bottom and destroying 6.54 acres of wetland. Major ground disturbing activity for the proposed development will also impact numerous unnamed feeder streams in the area, The project plan does not provide adequate information about storm water protection safeguards in case of excessive rainfall common to the headwaters --this area of the southeast regularly registers the highest rainfall amounts in the country, outside of Hawaii. To add insult to injury, the proposed sewer line for this high density development would go to the Cashiers wastewater treatment plant on the Chattooga Riverthat is already maxed at 200,000 gallons a day to protect the river, which is classified as Outstanding Resource Waters. The Chattooga is protected for a reason. Residents of the area and interested citizens have a right to full information and full review of these plans, which go against the public interest. I look forward to your announcement of a public hearing soon. David W CIV USARMY CESAW I From: Charlee Tisdale <t.charlee@yahoo.com> "JUN Q 6 2018 Sent: Wednesday, June 6, 2018 4:42 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Sourcel Development on Cashiers Lake -Charlee Tisdale Please allow a public hearing to hear all positions concerning development around Cashiers lake. This area contains the headwaters for a pristine Wild and Scenic River, and isn't there legal restriction for releasing water of poorer quality into a stream that crosses a state boundary as well? This matter needs to be discussed I There is developable land available in the Cashiers area which is not so strategic to maintaining the integrity of such a national treasure as the Chattooga Rlverlll I am imploring you to consider the consequences that development will have on this unique area. Charlee A. Tisdale Memberships: Appalachian Trail Conservancy Nantahala Hiking Club Bartram Trail Society National Parks Conservation Association David W CIV USARMY CESAW I ir 'f- 'JUN 0 6 7418 Y From: Doris Cooper <dhcfrc@att.net> Sent: Wednesday, June 6, 2018 4:31 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Nan-DoD Source] Proposed Development - Cashiers Lake - Doris Cooper PUBLIC HEARING - a MUSTI I ll I People who vote and pay taxes (your salary,etc.) have aright to—KNOW— about the proposed development on CASHIERS LAKE by a TEXAS developer. This development will impact the Chattooga River and its many tributaries used by millions of residents and visitors for recreation. The DETAILS need to be shared with the public and the public needs the opportunity to ask the developer questions! We all know from experience that developers are motivated by the $$$$ to be made and that when the consequences and damages ( both short and long range) follow the development they will be LONG GONEI II I PLEASE - out of respect for the environment and a sense of responsibility to the people that use and depend on this area - hold a PUBLIC HEARING for all those involved on all sides of this project. Thank YOU for your time and consideration. Doris Cooper- a voting resident of Georgia, a grandmother and great aunt to 13 grandchildren, nieces and nephews who recreate in this area. David W CIV USARMY CESAW l [JUN From: Harlan Collins <harlan@harlancollins.com> Sent•Wednesday, June 6, 2018 3:32 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non -Dob Source] resort & community development proposal at Cashiers Lake - Haden Collins I'd like to request a public hearing on the Texas developer's request to build a 100 -unit resort hotel and a 55 -home residential community on Cashiers Lake. am concerned about the possible impact on the Chatooga River (an Outstanding Resource Waters) and on the existing utilities in the area. Many thanks, in advance, for your consideration. Harlan Collins Harlan Collins harlan@hariancollins.com <mailto:harlan@hariancoilins.com> 314-720-2737 2018 Brown, David W CIV USARMY CESAW (US) From: John Pressley <johnpressleyS@gmail.com> Sent: Wednesday, June 6, 201 S 2:24 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Proposed Development Project on Chattooga-John Pressley Hello, I am emailing in response to the proposed development plans of Cashiers Lake. Please have a public hearing about this. This development would spell disaster for the surrounding environment and its inhabitants, not excluding us Iocals..We have had enough of our precious home land stolen and destroyed with subdivisions, country clubs, and golf courses. We have enough and do not need anymore 1 Please be aware and respectful to the animals that call this area home. They keep getting pressured more and more and nobody cares. It always comes down to money, but for once let it come down to what's the right thing to do. Please have a public hearing about this issue. Thanks. To 4--- - Brown, David W CIV USARMY CESAW (US) ALL From: ParkerAmmons <ammonsjp1996@gmail.com> f Sent: Wednesday, June 6, 2018 2:18 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Nom-DoD Source] request for public hearing on cashiers lake development - Parker Ammons JUST GOT WORD ABOUTTHE PROPOSED CASHIERS LAKE DEVELOPMENTTHAT WILL DtSTROY WETLANDS AND HAS THE POTENTIAL TO DESTROY THE CHATTOOGA RIVER AND FLOOD SURROUNDING AREAS. ALSO I HAVE BEEN TOLD THAT IT WILL VIOLATE PARAMETERS ALREADY IN PLACE TO PROTECT THE CHATTOOGA RIVER AT THE CASHIERS WASTEWATER TREATMENT PLANT. PLEASE CALL A PUBLIC HEARING ON THIS PROPOSED DEVELOPMENT. Thanks, Parker Ammons Brown, David W CIV USARMY CESAW (US) From: Michael Levine <ms3levine@yahoo.com> Sent: Friday, June 8, 2018 12:15 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Chattanooga Lake - Michael Levine rU PV. Dear Mr. Brown, The Chattooga River classified as "Outstanding Resource Waters" will be greatly impacted by a plan to dredge Chattooga Lake in order to build a hotel and a number of private homes. In addition, this development added to the current use of Cashier's wastewater treatment facility will exceed its current capacity. This is a great threat to a beautiful, pristine "National Wild and Scenic River". For these reasons I am requesting a PUBLIC HEARING. Sincerely, Michael S. Levine, MD Brown, David W CIV USARMY CESAW (US) From: Kathy Stilwell <graceplays@gmail.com> Sent: Friday, June S, 2018 9:35 AM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Request for Public Hearing - Kathy Stilwell j'I�ToITV5V l' QUN 0 8 2018 Mr. Brown, I am writing to you to request a "PUBLIC HEARING" . Citizens have the right to learn more about this potential threat to the longest and most pristine National Wild and Scenic River in the Southeastern U. S. I am referring specifically to Permit Program.aspx and Corp Action ID # saw -2076-00032. The applicant is Ms. Roseanne Giordani, Cashiers canoe Club Development Corp. LLC. Thank you in advance for honoring this request. Kathy Stilwell Franklin, NC g QUN 0 8 2018 f,> Brown, David W CIV USARMY CESAW (US) rbl,. From: Tara Stevenson <clemsontigergirl@gmail.com> Sent: Friday, June 8, 2018 9:12 AM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non -Doff Source] Public Hearing Chattooga River - Tara Stevenson I'm adding my name to the list of those requesting more information in the form of a public hearing on a proposed development that could impact the wild and scenic Chattooga river. Dredging the lake bottom and destroying 6.54 acres of wetland is frightening to me due to numerous unforeseen unknowns. Tara Stevenson 828-606-7383 clemsoptigergirl@gmail.com <mailto:clemsontigergirl@gmall.com> Brown, David W CIV USARMY CESAW (US) From: David Dostall <ddostall@yahoo.com> Sent.Friday, June 8, 2018 8:36 AMJT` To: Brown, David W CIV USARMY CESAW (US) Plt Subject: [Non-DoD Source] Cashiers Lake Dredging - David Dostall Dear Mr.Brown, am writing to express my concerns over the proposed development around Lake Cashiers. I strongly encourage that there be an extensive hearing process prior to permitting any developing or dredging here. This is a very sensitive area at the very headwaters of the Chattooga River a pristine and protected Wild and Scenic River. I understand that the developer wants to eliminate existing wetlands, and to dredge the lake. This is incredibly damaging to the ecosystem of not only the lake itself, but to the aquifers downstream. It is also my understanding that the developer wants to pump the effluent from his sewage system into the existing wastewater treatment system which is already running at full capacity. This will cause nothing but problems in the future. Please look at all of these issues and more and call for a thorough, comprehensive hearing process. Thank You, Best Regards, David Dostall Sent from my iPad Brown, David W CIV USARMY CESAW (US) From: Peter Peteet <pdmpeteet@gmail.com> 5enf•. Friday, June 8, 2098 6:55 AM ¢ �UJ1 jk+ Se • Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Dredging of Cashiers Lake -Peter Peteet Jr Dear Sir, Please hold a public hearing on this proposal as it will Impact the watershed downstream -including some of my favorite waters. Thanks, Peter Peteet Brown, David W CIV USARMY CESAW (US) From: Preston Oakes <preston.oakes@outlook.com> Sent: Thursday, June 7, 2018 6:41 PM To: Brown, David W CIV USARMY CFSAW (US) Subject: [Non-DoD Source] Chattooga River headwaters - Preston Oaks Mr. Brown, r QUN Q 9 1818 I am writing you to request a public hearing in regards to the permit applied for the headwaters of the Chattooga river. Because this developer's plans include dredging almost IS acres of lake bottom, destroying 6.54 acres of wetland, and causing major ground disturbing activity for the proposed development will also impact numerous unnamed feeder streams in the area, and because the project plan does not provide adequate information about storm water protection safeguards in case of excessive rainfall common to the headwaters I think a public hearing to hear the people who live and rely on the Chattooga have to think about this matter. Me and my friends kayak this river almost every week and we also eat and buy things in the local community. Not only would this be detrimental to the ecosystem and quality of the river but it would also damage the companies on and around this river. Thank you for your consideration, Preston Oakes Brown, David W CIV USARMY CESAW (US) From- SD2 <sandidonn2@yahoo.com> Sent: • Thursday, June 7, 2098 5:05 PM . To. Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Request for Public Hearing - 900 -unit r vend 55 -home residential community on Chattooga River - Donn Erickso [JUN 0 J7 2018 r. Mr. David Brown, pv. I am requesting that you hold a public hearing on the proposed 100 -unit resort hotel and 55 -home residential community on the Chattooga River. This project proposes to undertake a significant dredging operation with probable adverse impact to adjacent wetlands. Furthermore, the impact the project will have on the Cashiers wastewater treatment plant needs to be publicly discussed. This project offers a significant benefit to the community and needs to be undertaken in a fashion which will gather public support. Thanks you, Donn Erickson , David W CIV USARMY CESAW F From: Karen Lawrence <lawrencekrw@gmail.com> r Sent: Thursday, June 7, 2018 4:03 PM To. Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Public Hearing request - Corp Action iD# saw -2016-00032 -Karen Lawrence Please hold a public hearing about this proposal for disturbance of the headwaters of the Wild and Scenic Chattooga River. am referring to the application from Ms. Roseanne Giordani of Cashiers Canoe Club Development, LLC seeking Department of the Army authorization for dredging of the Cashiers Lake. The public has the right to learn more about this potential threat to our pristine river. It appears that there will be a major ground disturbing activity and destruction of 6.54 acres of wetland. There is no plan for storm water protection safeguards in case of excessive rain. Cashiers wastewater treatment plant on the Chattooga River is already maxed at 200,000 gallons a day. Thank you for this consideration. Karen Lawrence Brown. David W CIV USARMY CESAW (US) From: Torn Colkett <tcolkett@gmail.com>I'����"' "1 Sent:Thursday, June 7, 2018 2:05 PM To: Brown, David W CIV USARMY CESAW (US) i rJUN 0 7 1018 J] Subject: [Non-DoD Source] Cashiers lake Dredging - Tom Colkett PV. Mr. Brown, I have just learned of the intent of a Texas builder to dredge Cashiers Lake in order to build a luxury hotel and 55 home residential community. There are far too many negatives about this project to allow the permitting process to proceed without public input. To list just a few: - 6.54 acres of wetland will be destroyed. - the plan does not specify the handling of runoff water resulting from excessive rains. - the plan calls for tying the septic into the Cashiers wastewater management which is already maxed out at 200,000 gallons per day. - the wastewater management system is the last defense for the protection of the Chattooga river which is the longest and most pristine National Wild and Scenic River in the Southeastern United States. Considering the above factors I think it would be criminal to proceed without input from the community at large. Please schedule public hearings so that all concerned parties can speak to the issues on this terrible project. Also, I request that I be kept informed on any further developments regarding this matter. Thank you Thomas Colkett Brown, David W CIV USARMY CESAW (US) From: Marie Dunkle <mdunkle@mindspring.com> Af QUIN 0 i 2018 Sent: Thursday, June 7, 2018 11:02 AM To: Brown, David W CIV USARMY CESAW (US) r Cc: Mary Topa Subject: [Non-DoD Source] Dredging Cashiers Lake and threat to Chattooga - Marie Dinkle Dear Mr. Brown I am writing because of my concerning about a request for a permit from the US Army Corp of Engineers to dredge Cashiers Lake that feeds the headwaters of the Chattooga River. I understand that this is part of a development plan to build a hotel and residential community in the area. 1 also understand that this may involve dredging almost 18 acres of lake bottom and will impact wetlands. This activity would likely produce major grounds disturbing activity and impact numerous feeder streams in the area. I am concerned about adequacy of storm water protection in the case of excessive rainfall that is common in the headwater, as well as a proOosed sew line associated with the project that may impact the Chattooga River which is classified as outstanding resource waters. A public hearing should be called on this matter before any more action is taken or project approvals are given to the developer. Please hear the voices of those of us who live in the area and downstream from this potential activity. Thank you. Sincerely, Marie K. Dunkle 726 Saga Mtn Road Tiger GA 30576 770-335-0967 mdunkle@mindspring.com <mailto:mdunkle@mindspring.com> Brown, David W CIV USARMY CESAW (US) 1AI To R ra T' T, ft From: Elizabeth Lide <elizabethlide@bellsouth.net> 'JUN 0 7 2018 Sent: Thursday, June 7, 2098 9:55 AM To: Brown, David W CIV USARMY CESAW (US) 1n - Subject: [Non-DoD Source] Hearing about Cashiers Lake -Elizabeth Lide Please hold a public hearing about the proposed dredging of Cashiers Lake that feeds the headwaters of the Chattooga River. Citizens need to know much more about the plan to build a 100 -unit resort hotel and a 55 -home residential community there . The Chattanooga River is the longest and most pristine National Wild and Scenic River in the Southeastern U. S. This proposal to dredge and build is a most serious one and if that takes place, there is no going back to its pristine designation. We do not want to Sincerely, Elizabeth Lide , David W CIV USARMY CESAW I 0 - From: From: Geoff Page <geof inalaska@hotmaiLcom> �?� t• r Sent: Thursday, June 7, 2018 9:48 AM To: Brown, David W CIV USARMY CESAW (US) pa Subject: [Non-DoD Source) Cashiers/Chattooga development - Geoff Page Dear sir, I have learned of plans of additional development near Cashiers, NC, that would significantly impact the Chattooga Wild & Scenic River. A designation bestowed on very few waterways lett in the U.S. The Cashiers wastewater treatment plant Is already operating at maximum, and additional residents would cause discharge of untreated waste into a nearly pristine environment. I implore you, please DENY any permits that would endanger this precious natural setting Geoff Page . Br rrown. David W CIV USARMY CESAW {US) iun 0 8 2012' From: Abby Perrin <aPerrin192@gmail.com> r Sent: Friday, June 8, 2018 12:50 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-Dol) Source] Requesting a Public Hearing on the Dredging of Cashiers Lake- Abigail Perrin Dear Sir, As a concerned citizen and user of the Wlld&Scenic Chattooga River and it's watershed, I wish to demand a public hearing concerning the request for a permit to dredge Cashiers Lake in preparation for the development plan. Ground disturbing activity for the development will impact numerous unnamed feeder streams and aquatic life. The project plan does not provide adequate information regarding storm water protection safeguards in case of excessive rainfall common to the headwaters. The proposed sewer line for this high density development would go to the Cashiers wastewater treatment plant on the Chattooga River that is already capped and maxed at 200,000 gallons a day to protect the river, which is classified as Outstanding Resource Waters. A public hearing is necessary for myself and other citizens to weigh in on this proposed action that impacts federal lands. Thank you for your consideration. Abigail Perrin Resident of Long Creek SC Sent from my Whone Brown, David W CIV USARMY CESAW (US) From: James Riddle <riddle4iu@gmaii.com> Sent: Friday, June 8, 2018 1:97 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Fwd: Chattooga Lake Dredging and Building Project _James Riddle J.R. )VIMP WN08 2018 ' �v. Forwarded message ---- From: James Riddle <riddle4iu@gmail.com <maIIto:riddle4iu@gmalI.com> > Date: Fri, Jun 8, 2018, 1:13 PM Subject: Chattooga Lake Dredging and Building Project To: <David.W.Brown@auacee.army.mil <ma!Ito:David.W.Brown @auacee.army.mii> > Sir, I writing this to formally request a public hearing to learn and discuss the impacts of this project on the environment. Dredging the lake will essentially destroy several acres of wetlands and negatively impact a number of feeder streams In the area. I believe people living in and using the area should have benefit of a hearing to learn more of the project and to express their concerns. James Riddle 820 Cullasaja Club Dr Highlands, IAC 28741 828-5264286 David W CIV USARMY CESAW From: Laurens Pitts <laurensmpitts@gmail.com> rJUN 0 g 20TO Sent: Friday, June 8, 2018 1:47 PM To: Brown, David W CIV USARMY CESAW (US) FV: Cc: James Riddle . Subject: [Non-DoD Source] NEPA - Cashiers Lake Development - Laurens Pitts I request a copy of the National Environmental Protection Act (NEPA) documentation for the subject project be forwarded to me and any comment percid be extended for 30 days to provide adequate review. Until today I was unaware of the proposed development adjacent to Cashiers Lake. An email copy will be sufficient. My address is - Laurens M Pitts, P.E. 3400 Upper Whitewater Rd Sapphire, NC 28774 Thank you - Laurens Pitts Brown, David W CIV USARMY CESAW (US) From: Michael Dupuis <mdupuis46@yahoo.com>TIP ' Sent:Friday, June 8, 2018 1:36 PM Brown David W CIV USARMY CESAW (US) `'�U $ 201 70: f Subject: [Non -Doll Source] dredging - Michael Dupuis PV. Would like a public hearing on dredging of the lake in Cashiers.. Many things do not add up concerning this project. Sewer system is already to capacity. Need more input....don't want to take ANY chances on polluting our beautiful riverl Respectfully, Martha and Michael Dupuis Highlands NC Brown, David W CIV USARMY CESAW (US) From: bryding Adams <brydingadams@gmail.com> Sent: Friday, June 8, 2018 2:01 PM it 'JUN 0 E, 201$ !. To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Request for Public Hearing - Bryding Adam pe. on a private developer who wants to dredge Cashiers Lake and develop houses and a resort hotel. These waters are an Important part of the Chattooga River water system, plus provide wetland habitat for local flora and fauna. There needs to be more information on storm water protection safeguards and wastewater treatment from such a large development. The Chattooga River is of course the longest and most pristine National Wild and Scenic River in the southeastern U. S. Nothing should be developed that would threaten it any way. Citizens have a right to know more about this potential development. A public hearing will be greatly appreciated. Thank you. Sincerely, Bryding Adams 3525 Turtle Pond Road Highlands, NC 28741 Brown, David W CIV USARMY C>E:SAW (US) From: garyturnley@nctv.com Sent: Friday, June 8, 2018 4:04 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [EEMSG-SPAM: Suspect][Non-DoD Source] Request for public hearing re Cashiers Lake NC - Gary & Pamela Tunrley My wife and I live in Cashiers, NC. Our address is 122 Caroline Lane P.O. Box 885 Cashiers, NC 28717-0885. We are opposed to dredging Cashiers Lake as it feeds the Chattooga River, which is the longest pristine river in the S.E. United States. �-�rp�irilT�i�t JUS Q 8 2018 As citizens we request a public hearing on this important matter. FAV Gary and Pamela Turnley "JUN 0 8 2018 Brown, David W CIV USARMY CIESAW (LI From: Beverly Clark <banjobev@aim.com> Sent: Friday, June 8, 2018 3:55 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Nan-DoD Source] Public Hearing Requested -Chattooga River Threat -Beverly Clark A public hearing must be held on this projectl The plan does not provide adequate information regarding storm water protection safeguards in case of excessive rainfall common to the headwaters. The proposed sewer line for this high density development would go to the Cashiers wastewater treatment plant on the Chattooga River that is already capped and maxed at 200,000 gallons a day to protect the river, which is classified as Outstanding Resource Waters. Beverly Clark 1�rtas��tnns� 1 -JUN 0 8 1018 Brown, David W CIV USARMY CESAW (US) From: gerri tulley <walk1ng50@live,com> Sent: Friday, June 8, 2018 345 PM To: Brown, David W CIV USARMY CFSAW (US) Subject: [Non -Dob Source] Proposed dredging of Cashiers fake - Gerri Tulley Dear Mr.Brown, It was brought to my attention that a developer plans to dredge Cashiers Lake in order to build a hotel and residential area. I would like to request a public hearing as I am opposed to this action. When will we stop destroying nature for human benefit? This would destroy 6.54 acres of wetland and impact numerous feeder streams In the area. The project plan does not provide adequate information about storm water protection safeguards in case of excessive rainfall common to the headwaters. There is not adequate sewer provisions as the Cashiers wastewater treatment plant could not handle this high density development putting the Chattooga River at risk. I and my neighbors have a right to learn more about this potential threat to the longest and most pristine National Wild and Scenic River in the Southeast U.S. Please respond to my request. Thank you, Gerri Tulley Highlands, NC Sent from my iPhone Brown, David W CIV USARMY CESAW (US) From: Susan May <susanrmayl @gmail.com> Sent: Friday, June 8, 2018 3:36 PM it ,,iUN 0 8 2018 3� To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Request for Public Hearing - Susan May RY. As a citizen of the Highlands/Cashiers, NC area I am requesting a public hearing so as to have a better understanding of the project being planned for Cashiers Lake which feeds the Chattooga River. My understanding at this point is that their is a request for the Army Corp of Engineers to dredge Lake Cashiers. 1 believe that the citizens of the area need to acquire a better appreciation of the dredging and the total plan of the project. Thank you, Susan May Brown, David W CIV USARMY CESAW (US) From: Jim Ward gward@ward-scott.com> Sent: Friday, June 8, 2018 3:21 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Cashiers Lake proposed development - JiWard W In ;,dun n 8 201$ Mr. Brown, :! 9' y , A proposed large development project in the Cashiers Lake area has been brought to my attention. There are many concerns and unanswered questions about this large development in the precious headwaters of the Chattooga. It is vital to inform the community about the development and particularly the safeguards to the environment that will be implemented. Why will the lake be dredged? Why will wetland habitats be lost? What will be done to protect the waters of the Chattooga? Is the local water and sewer infrastructure able to serve this project or will improvements need to be made? A public hearing is needed and should be mandatory for this type/size development. Please do not proceed with this project without due diligence to inform the community, to allow the community to comment, and to verify that all impacts to the environment are manageable and fair. Thanks for your attention to this. Jim Ward 133 Oak Lane Highlands, NC 28741 James W. Ward, Principal Ward Scott Architecture, Inc. 2715 Seventh Street Tuscaloosa, AL 35401 B 205.345.6110 D 205.247.3212 Brown, David W CIV USARMY CESAW (US) From: Diane Levine <diane.t.levine@gmail.com> ToITVTe Sent: Friday, June 8, 2018 3:18 PM To: Brown, David W CIV USARMY CESAW (US) Q U N 0 8 8 Subject: [Nan-DoD Source] Chatooga River - Diane Levine RYA ....... This is my request for a public hearing regarding Cashiers, and our seeet Chatooga River Diane Levine 828-536-8579 Brown, David W CIV USARMY CESAW (US) From•. Angie Ramey <hamramey@yahoo,com> Sent:Saturday, June 9, 2018 11:50 AM 7o• Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Chatooga river and Cashiers Lake Dredgimg - Angie Ramey Dear Sir: Many in our community are extremely upset as to the possibility of establishing a permit that could affect the "little" people downstream. We would appreciate a public hearing to discuss this and a complete hold placed on any permits to add more waste to our river that could have a negative effect on wildlife and toxic levels. We would personally like to hear what measures will be taken to ensure adequate sewage containment for a facility that is already over the limit NOW, how future testing of our beautiful river will be done to ensure safe levels in the future if this is permit is approved. I would hope to see an erosion impact study, wildlife impact study and polution impact study prior to the passage of such permit..i would also like to see the required guidelines for permitting for this construction and what construction permit precations are for such a undertaking to ensure silt and debris doesn't pollute or beautiful river .... We need a public hearingM Sincerely, Angela Ramey Permit Coordinator Engineering Dept Quanta Services Concerned Citizen 79 fflu pp T- rJUN # 1 2018 PV Sent from Yahoo Mail on Android <Blockedhttps://go.onelink.me/107872968?pid=lnProduct&c=Global_Internal YGrowth Android EmailSig_AndroidUser s&af wl=ym&af subl=internal&af sub2=Global—YGrowth&af sub3=EmailSignature> Brown, David W CIV USARMY CESAW (US) From: Shane Benedict <shane@liquid[ogickayaks.com> Sent: Friday, June 8, 2018 5:21 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Public Hearing about Dredging Cashiers Lake - Shane Benedict There should be a public hearing about this proposed permit for dredging Cashiers Lake for proposed development. Rumor has It that a Texas developer has applied for a permit from the U.S. Army Corps of Engineers to dredge Cashiers Lake, as part of a plan to build a 100 -unit resort hotel and a 55 -home residential community there. Dredging almost 18 acres of lake bottom and destroying 6.54 acres of wetland. Ground disturbing activity for the development will also impact numerous unnamed feeder streams and aquatic life. The project plan does not provide adequate information regarding storm water protection safeguards in case of excessive rainfall common to the headwaters. The proposed sewer line for this high density development would go to the Cashiers wastewater treatment plant on the Chattooga River that is already capped and maxed at 200,000 gallons a day to protect the river, which is classified as Outstanding Resource Waters. Thank you Shane Benedict QUN 0 8 1018 PV' ...... Brown, David W CIV USARMY CESAW (US) From: Clay Nash <nash.clay.rn@gmail.com> Sent: Friday, June 8, 2018 4:54 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Proposed develompment in Cashiers - Clay Nash HI, I am opposed to the proposed development on Cashiers Lake. The plan calls for destruction of wetland in the headwaters of a Wild and Scenic Watershed. The development would send wastewater to a system that is already maxed out. Please call for a public hearing for citizen input. Clay Nash [JUN Q 8 1018 Brown, David W CIV USARMY CESAW (US) From: Mary Topa <mtopa@gafw.org> Sent: Monday, June 11, 2018 11:13 AM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Dredging Cashiers Lake and threat to Chattooga - Mary Topa nIF or, - Dear Mr. Brown, 91.i WUN ) ) 2018 I am writing because of our concern about a permit request from the U.S. Army Corp of Engineers to dredge Cashiers Lake that feeds the headwaters of the Chattooga River. I understand that this is part of a development plan to build a 100 -unit hotel and 55 -home residential community in the area. The proposed dredging of almost 18 acres of lake bottom, destruction of 6.5 acres of wetlands, and major ground disturbing activities for the proposed development will increase sedimentation of unnamed feeder streams and likely impact aquatic wildlife. The project plan does not provide adequate information about storm water protection safeguards in case of excessive rainfall common to the headwater area. The proposed sewer line for this high-density development would go to the Cashiers wastewater treatment plant on the Chattooga River that is already maxed at 200,000 gallons a day, posing a threat to this Outstanding Resource Waters. A public hearing should be called on this matter before any more action is taken or project approvals are given to the developer. Recreational users of this wonderful resource, and citizens who live in the area or downstream from this potential activity have a right to know more about the project, and the potential threat it poses to the longest and most pristine National Wild & Scenic River in the Southeastern United States. Regards, Mary A. Topa Mary A. Topa, Ph.D. Executive Director Georgia ForestWatch 81 Crown Mountain Place Building C, Suite 200 Dahlonega, GA 30533 (706) 867-0051 Brown, David W CIV USARMY CESAW (US) From: Laurens Pitts <laurensmpitts@gmail.com> a Sent: Monday, June 11, 2098 12:54 PM To: Brown, David W CIV USARMY CESAW (US) [JUN 1 12018 Cc: James Riddle Subject: [Non -DOD Source] Re: NEPA - Cashiers Lake Development plr In addition to the National Environmental Policy Act documentation, I would like to see all State and Army Corps of Engineers permits for the subject projects. - Laurens Pitts On Fri, Jun 8, 2018 at 1:47 PM, Laurens Pitts <laurensmpitts@gmail.com <mailto:laurensmpitts@gmall,com> > wrote: I request a copy of the National Environmental Protection Act (NEPA) documentation for the subject project be forwarded to me and any comment peroid be extended for 30 days to provide adequate review. Until today I was unaware of the proposed development adjacent to Cashiers Lake. An email copy will be sufficient. My address is - Laurens M Pitts, P.E. 3400 Upper Whitewater Rd Sapphire, NC 28774 Thank you - Laurens Pitts ��s'-To C- n' .r, F %1114 • .1 Rn• A, `5 Brown, David W CIV USARMY CESAW (US) From: Roger Nott <rogernott@aft. net a Sent Monday, June 11, 2018 7:38 PM To: Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Permit request to dredge Cashiers Lake - Robert Nott Dear Mr. Brown: This will request that you schedule a public meeting regarding the permit application to dredge Cashiers Lake as part of a plan to build a 100 -unit resort hotel and a 55 -home residential community there. The dredging of almost 18 acres of lake bottom and destruction of 6.54 acres of wetland threatens the pristine Chattooga River, and ground disturbance for the proposed development could negatively impact numerous feeder streams in the Chattooga headwaters. The project plan does not provide adequate information about storm water protection safeguards in case of excessive rainfall common to the headwaters. The proposed sewer line for this high density development would go to the Cashiers wastewater treatment plant on the Chattooga River that is already maxed at 200,000 gallons a day to protect the river, which is classified as Outstanding Resource Waters. Thank you for your national service and consideration. Roger E. Nott Gainesville, GA 678-316-4935 Brown, David W CIV USARMY C£SAW (US) From•_ Adam Hackenberg <adam.my.hackenberg@gmail.com> Sent Thursday, June 14, 2018 2:39 PM To• Brown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Public hearing development - Adam Hackenberg Does cashiers have enough capacity at there wastewater facilities to handle the new resort. How much damage will be done to wetlands areas in surrounding areas. Are the stormwater protections going to be adequately put into place. The public needs a. hearing. From: Starr Silvi To: Brown, David W CIV USARMY CESAW (US Subject: [Non -DOD Source] Chattooga River - Starr Silvis Date: Wednesday, June 06, 2018 8:59:39 AM Dear Mr. Brown, I am writing to request a public hearing for the proposed development on the Chattooga River Headwaters. The application is for dredging of Cashiers lake. The impacts of this proposed action are far reaching and in direct opposition to the protections intended by Nationals wild and Scenic designation. I am a water resources engineer who was in charge of NCDENR 401 certifications in the ARO for several years. The area where this project is proposed is one of the highest rainfall areas in the US. It is also an Outstanding Resource water. There must be special measures taken to assure stormwater management for frequent and heavy rains. This includes any dredging activities and development activities. I have worked with many projects in that area and all have had problems related to lack of understanding and proper preparation and planning for the frequent and heavy rainfalls experiences in that area. Furthermore, dredging will impact over 6 acres of headwater wetlands which are integral to to health of the Chattooga River. Please Feel free to contact me with any questions and put me on the contact list for any public information regards if activities in that watershed. Sincerely, Starr Silvis, MS PE From: Barrett r. To: Brown. David W CIV USARMY CESAW (US) Subject: [Nan-DoD Source] Public hearing - Barrett Barker Date: Wednesday, June 06, 2016 10:25:08 AM Kind sir, I am writing to appeal to you to call for a public hearing regarding the Texas developer who has applied for a permit from the U.S. Army Corps of Engineers to dredge Cashiers Lake in the headwaters of the Chattooga River as part of a plan to build a 100 -unit resort hotel and a 55 home residential community. Dredging almost 18 acres of lake bottom will destroy 6.54 acres of wetland. Ground disturbing activity for the development will also impact aquatic life in feeder streams. The project plan does not provide adequate information regarding storm water protection safeguards in case of excessive rainfall common to the headwaters. A sewer line for this high density development will stress the wastewater treatment plant on the Chattooga River that has been capped at 200 thousand gallons a day to protect the river that is classified as Outstanding Resource Waters. live in Oconee county, SC and use the Chattooga for recreation and personal wellbeing. My family cherishes the natural beauty and pristine experiences provided by the river, and I believe maintaining the current natural state without degradation of the water quality upstream is paramount to keeping the Chattooga wild and scenic. Please do your duty and provide the citizens the ability to have a voice in the proposed development above the headwaters. Thank you. Barrett Barker CLEMSON UNIVERSITY Department of Physics and Astronomy Physics and Astronomy Research Lab bbarkerPclemson.edu 864-656-5311 From: Jacob Cooper To: grown, David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] Public Hearing Request - Cashiers Lake Dredging and Development - Jacob Cooper Date: Wednesday, June 06, 2018 12:22:03 PM Hi David, I would like to voice my concerns and add a request for a public hearing about the non -extensive nature of stormwater management plans for the proposed dredging and development on Cashiers Lake, which could potentially affect the water quality of the Chattooga River and numerous tributaries both upstream and downstream of the lake. Another major concern is the feeding of sewer lines from the development into the Cashiers wastewater facility, which is already running at maximum capacity for the purpose of protecting the river. The Chattooga is a National Wild and Scenic River, as I'm sure you know, and is an invaluable resource for thousands of people. It is worth protecting in as many ways as possible. Thank you for your time. Respectfully, Jacob Cooper Environmental Economics and Management UGA 2018 idcooper�Zuga.edu Personal and/or Business Inquiries: icoopermedia Rgma il.com From: Chattooaa Conservan To: Brown. David W CIV USARMY CESAW (USl Subject: [Non-DoD Source] Public hearing request Date: Monday, June 04, 2018 7:59:22 AM am writing to request a public hearing regarding the proposed development on Cashiers Lake in Cashiers N. C. to explore concerns for the possible impact to the water quality and aquatic ecosystems in the Chattooga National Wild and Scenic River related to ground disturbing activity, wetland dredging and stream disturbance. Buzz Williams, Chattooga Conservancy Chattooga Conservancy info(@ chottooaariver.or. 9 Sequoia Hills Lane Clayton, GA 30525 teL 706.782.6097 Blocked www. chattoogoriver. ora From: NANCY T JAMES T0: Brown, Subject: [Non-DoD Source] Public Hearing Date: Wednesday, June 06, 2018 8:04:54 AM I would like to request a public hearing to discuss the potential threat to our National Wild and Scenic River. I've heard that a permit has been applied for to dredge Cashiers Lake as part of a plan to build a residential community. More information is needed and a discussion is warranted based on the damage to the wetlands, the danger to the aquatic life, the strain this could cause on the wastewater treatment plant, among other things. Thank you for your consideration. Nancy T. James '89 Research Analyst From: Nick Terry To: Brown. David W CN USARMY CESAW (US) Subject: [Non-DoD Source] Request for a public hearing - Cashiers Lake Development and Dredging- Nick Terry Date: Wednesday, June 06, 2018 11:59:20 AM Mr. Brown, I would like to request a public hearing on the proposed plan to dredge Lake Cashiers to support a resort and residential development. Lake Cashiers is an important feeder of the Chattooga River headwaters, and dredging the lake would impact the oldest federally designated Wild and Scenic river in the United States. In addition, I have concerns regarding the planned use of the Cashiers wastewater treatment plant to support the development. Relying on the Cashiers plant for this development would negatively impact the water quality of the Chattooga River, an important source of tourism and economic benefit for many communities downstream. Protecting the Chattooga River and its headwaters is important to many surrounding communities. Please take the above into consideration, and push for a public hearing on the matter. Thank you for your time. Nick Terry 770 826 0699 From; Kathv Edwards To: Brown. David W CIV 115ARMY CESAW 1115] Subject: [Non -DOD Source] Request for public hearing on development plans for Cashiers Lake area. - Kathy Edwards Date: Wednesday, June 06, 2018 4:59.21 PM Dear sir, I have just learned that a Texas developer has applied for a permit from the U.S. Army Corps of Engineers to dredge Cashiers Lake as part of a plan to build a 100 -unit resort hotel and a 55 -home residential community there. Cashiers Lake feeds into the headwaters of the Chattooga River, the longest and most pristine National Wild and Scenic River in the Southeastern U. S. I am writing to request a public hearing on this permit application and its consequences. This developer's plan includes dredging almost 18 acres of lake bottom and destroying 6.54 acres of wetland. Major ground disturbing activity for the proposed development will also impact numerous unnamed feeder streams in the area. The project plan does not provide adequate information about storm water protection safeguards in case of excessive rainfall common to the headwaters --this area of the southeast regularly registers the highest rainfall amounts in the country, outside of Hawaii. To add insult to injury, the proposed sewer line for this high density development would go to the Cashiers wastewater treatment plant on the Chattooga River that is already maxed at 200,000 gallons a day to protect the river, which is classified as Outstanding Resource Waters. The Chattooga is protected for a reason. Residents of the area and interested citizens have a right to full information and full review of these plans, which go against the public interest. I look forward to your announcement of a public hearing soon. Best regards, Kathy Edwards From: Charlie Mize To: Brown. David W CIV USARMY CESAW (US) Subject: [Non-DoD Source] There should be a public hearing regarding the proposed Cashiers Lake dredging - Charlie Mize Date: Wednesday, June 06, 2018 9:02:38 PM Hi Mr. Brown, I am writing to request a public hearing regarding the permit which has been applied for to dredge Cashiers Lake. The dredging would destroy 6.54 acres of wetland in the headwaters of the longest and most pristine National Wild and Scenic River in the Southeastern US. The plan does not provide adequate information about safeguards for heavy rainfall, and the sewer line for the whole development would put the Cashiers wastewater treatment plant over its capacity. Since the river is such a valuable resource, there should be a public hearing in which people can voice any concerns over its protection or lack thereof. Sincerely, Charlie Mize Master of Env. Mgmt & Master of Forestry Candidate 2019 Nicholas School of the Environment I Duke University charles.mize@duke.edu 1336-524-3277 Attachment B Updated Stream & Wetland Impact Map, Figure 3, Revised April 11, 2019 Cashiers Lake Development ( +/- 89 AC) Impact #13 Proposed laydown yard and maintenance access Wetland Fill (1951-1998) - 0.36 AC Impact #14 Proposed Forebay Construction Wetland Fill (1951-1998) - 0.21 AC Impact #15 Proposed Temp. (2) 48" CMP Culverts Wetland Impact: 30 LF I Impact #11 Proposed Bulkhead & Wetland Fill (1951-1998) - 0.21 AC Impact #10 Proposed Dredging Wetland (1951-1998) - 5.07 AC Impact #9 Wetland (1951-1998) Fill - 0.03 AC IJ proposed bridge no impact existing foot bridge I r proposed bridge no impact Tuckaseigee Water & Sewer Authority Legend = Existing Houses Proposed Site Plan Proposed Wetland Fill (Without Bulkhead) _ Proposed Bulkhead & Fill Out Parcel Wetlands Avoided Stream Proposed Wetland Dredging - 1998 Wetland Project Boundary 30' ORW Buffer Jackson County, North Carolina 0 o� O Forebay Cashiers Lake Impact #5 Proposed Bulkhead & Open Water Fill - 0.87 AC LandDesign. PROJECT DATA — 0.91AC TOTAL PROJECT AREA — 89AC JURISDICTIONAL WATERS OF THE US — 7.13 AC Streams — 5,332 LF Wetlands — 12.31AC Open Waters — 18.99 AC JURSIDICTIONAL IMPACTS Total Permanent Stream Impacts - 0 LF Wetlands (Fill) — 0.91AC Wetland (Dredge) — 6.22AC Total Wetland Impacts — 7.13 AC Open Water(Fill) — 1.39 AC Open Water (Disturbance) — 3.34 AC Total Open Water Impacts — 4.73 AC AVOIDANCE/MINIMIZATION Streams — 5,212 LF Wetlands — 5.18 AC Open Waters — 14.26 AC MITIGATION Streams N/A Wetlands (Payment to DMS) 8.82 AC Impact #12 Proposed Dredging Wetland (1998 -Present) - 1.15 AC Impact #1 Proposed Disturbance Open Water - 3.34 AC Impact #2 Proposed Bulkhead & Open Water Fill - 0.52 AC Impact #3 Proposed Bulkhead & Wetland (1998 -Present) Fill - 0.10 AC 'I Cash�e�sCd ke R °aa 6 0 250 500 1,000 Feet CLearWal:er 32 Clayton Street Asheville, North Carolina 28801 Revised 4/12/19 Stream & Wetland Impact Map Figure 3.0 Attachment C TWSA Letter TUCKASEIGEE WATER & SEWER AUTHORITY SERVING JACKSON COUNTY 1246 West Main Street Sy1va, NC 28779 Phone: (828) 586.5189 • Fax: (828) 631-9489 October 25, 2018 Cashiers Canoe Club Development, LLC Roseanne Giordani, Manager PO Box 300849 Austin, TX 78703 Re: Confirmation of Sewer Allocation Cashiers Canoe Club Development, LLC Dear Ms. Giordani: This letter is written as a follow up to your request to provide a summary of the sewer allocation held on various properties owned by The Cashiers Canoe Club Development, LLC or the underlying entities such as the Property Owners Association and Lake Association. The attached documents are provided to help address this request. Based on the table attached the total allocation held on the identified properties owned by Cashiers Canoe Club Development, LLC is 58,365 Gallons Per Day, of which two properties are currently connected to TWSA sewer. The net balance of the allocation is held on properties that are not connected, with a total of 55,785 Gallons per Day in that status. The sewer allocation held by Ca$hiers Canoe Club Development, LLC and not yet connected to TWSA is part of the sewer allocation that is "Not Realized" at that plant as part of our flow management. This 55,785 Gallons per Day of treatment capacity is thus reserved in the total 200,000 GPD of capacity of the existing Cashiers Waste Water Plant. The future acceptance of this 55,785 Gallons per Day of non -industrial sewage is within the design treatment capacity of 200,000 GPD plant and can be treated to.. meet, the discharge limits as set in the current NPDBS .Permit ' NC0063321. No new treatment capacity is needed to accept these flows at the current plant. So long as any applicable fees remain current with TWSA, the above listed 55,785 GPD of sewer capacity remains available for use until it is connected to the TWSA Sewer System. It is also to be noted that that the current TWSA Cashiers Sewer Transfer Policy does allow multiple transfers between properties, and the original 10% Transfer Fee has also been removed. These transfers may occur as allowed by the "Transfer Policy" provided that the proposed transfers can be served by collection system connections to the current plant. Page 2 October 25, 2018 Cashiers Canoe Club Development, LLC We hope this letter and attached tabulation addresses your request for information. Questions on this matter can be directed to me at 828-586-5189, Ext 203, or email at dharbaugh@twsanc.us. Resectfully Yours, Daniel E. Harbau Executive Directo Tuckaseigee Water & Sewer Authority Enclosure: Tabulation of Sewer Allocation Held & Supporting Documents CC. Files Turner Inscoe (Via Email) TUCKASEIGEE WATER AND SEWER AUTHORITY- TABULATION OF SEWER ALLOCATION HELD BY CASHIERS CANOE CLUB DEVELOPMENT LLC MAP ID PIN DESCRIPTION GPD SEWER CONNECTED? A 7572-40-0458 Cashiers Canoe Club Development/Formerly Blanc property (1.8 Acres) 0 NO B 7572-30-7062 Cashiers Canoe Club Develbpmersf/Forrherly Monday property (i1.9 Acres) 480 YES C 7571-39-1928 Cashiers Canoe Club Development/Formerly Straight 8 (2.1 Acres) 0 NO D 7571-38-3047 Cashiers Canoe Club Development (24.9 Acres) 30600 NO E 7571-29-9493 Cashiers Canoe Club Development (0.3 Acres) 0 NO F 7571-39-0470 Cashiers Canoe C(ub DeVelop`nerit (0.3 Acres) 0 NO G 757139-1335 Cashiers Canoe Club Development (0.2 Acres) 0 NO H 7571-39-1289 Cashiers;Canoe.Club Development (0:2 Acres) 0 NO ! 7571-39-2223 Cashiers Canoe Club Development (0.3 Acres) 0 NO J 7571-39-2166 Cashiers Canoe Club Development (0.3 Acres) 0 NO K 7571-39-1077 Cashiers Canoe Club Development (0.3 Acres) 0 NO L 7571-39-3025 Cashiers Canoe Club Development (0.6 Acres) 0 NO M 7571-38-2935 Cashiers Canoe Club Development (0.3 Acres) 0 NO N 7571-08~3980 Cashiers Canoe. Clubbeve(opment (0.5 Acres) 0 NO O 7571-38-2834 Cashiers Canoe Club Development (0.5 Acres) 0 NO P 7571-38-2734 Cashiers Canoe Club'Development/F.60jee ly Costello (0.9 Acres) 0 NO Q 7571-38-1713 Cashiers Canoe Club Development (0.2 Acres) 0 NO R 7571-08-1621 Cashiers Canoe Club Development (0.2 Acres) 0 NO S 7571-38-1523 Cashiers Canoe Club Development (0.2 Acres) 0 NO T 7571-3&1426 Cashiers Canoe Club Development (0.2 Acres) 0 NO u 7571-38-1307 Cashiers Canoe Club Development (0.2 Acres) 0 NO v 7571-38-0837 Cashiers Canoe Club Development (0.8 Acres) 0 NO W 7571-38-3464 Cashiers Canoe Club Development (1.7 Acres) 0 NO X 7571-39-9188 Lake Association (23.1 Acres) 0 NO Y 7571-38-5825 Canoe Club POA (0.4 Acres) 0 NO Z 7571-48-3379 Cashiers Canoe Oub Development/Formerly Hooper Ptoperty (7.0 Acres) 0 NO AA 7571-38-9432 Cashlers Canoe Club Development/Formerly Hooper Property (0.1 Acres) 0 NO BB 7571-37-9705 Cashiers Canoe Club Develo ment/Formerly Palmetto of SC (98 Acres) 0 NO CC 7572-11-8912 Cashiers Canoe Club Development/ Hardees Assemblage NO DD 7572-21-3905 Cashiers Canoe Club' Development/ Hardees Assemble a 25185 NO EE 7572-21-0616 Cashiers Canoe Club Development/ Formerly Hardees 2100 YES 25 OCTOBER, 2018 TOTAL GALLONS PER DAY TOTAL 58365 Gross UNREALIZED GALLONS PER DAY 55785 Net February 24, 2005 Mr. Phillip Ward, ASLA PO Box 2742 Cashiers, NC 28717 Dear Sir: Thank you for your timely response to our conversation. Timely from TWSA, and I will trust also for your principals, position in that decisions made in the next 90 -days will:; , r ' have long term consequences for Blue Ridge Estates, adjoining properties and Cashiers as a destination. To further clarify this statement I would indicate that the TWSA does not now have the wastewater treatment capacity nor can the collection system provide service to the development you are proposing. Given the time necessary for engineering, permitting and infasturture improvements, it will take TWSA to accommodate the demand to be placed upon its systems by this project, every month counts in an effort to insure that your clients can move forward in accordance with their respective business plan. With respect to your questions please consider the following: Wastewater Treatment Demand . The TWSA Board of Directors allocates wastewater treatment capacity in accordance with NC Administrative Code 15 NCAC 18A.1949. The demand calculations be]ow are to be considered as estimates until additional architectural and engineering information are provided to TWSA regarding the proposed project. Hotel - 27,400 sf with 52 rooms and 8 full time employees' equivalents 52 rooms x 120 gpd/room + 8 R emp eq. x 25 gpd = 6,440 gpd Pool and fitness Center 5,700 sq ft + 5 full time employee equivalents 10 gallons/person x 250 persons/day + 5 ft emp eq. x 25 gpd = 2,625 gpd Conference Center a 1,300 scats + 20 full time employee equivalents 1,300 seats x 5 gallon/seat + 20 ft emp eq x 25 gpd = 6,500 gpd Restaurant with 125 scats and 12 full time employee equivalents 125 seats x 40 gpd/seat.+ 12 ft emp eq. x 25 gpd = 5,300 gpd 12 tluee bedroom cottages x 120 gpd/bedroom x 3 bedrooms ea. = 4,320 gl) 25,185 gpd Tt 1 , ASEIGEE WATER & SEWER Al )Tl JORITY SERtl1NC1 JACKSON COUNTY 1246 V(Aest Alain Street April 12, 2016 To Whom It May Concern; Sylva, NC 26779 7Y Thune: (828) 586-5189 s fax: (828) 6.31.9099 J b;j PIL C This is to confirm that Blue Ridge Estates has sewer allocation from Tuckaseigee Water & Sewer Authority for 25,185 gallons per day on Property ID #7572-11-8912 and #7572-21- 3905. In the event Blue Ridge Estates decides to sell the properties, the 25,185 gpd would remain with the properties unless a transfer of allocation was requested and approved according to the TWSA Allocation Transfer Policy's requirements. I am including a copy of a Cashiers Sewer Allocation Fact Sheet and a letter from February 2013 referring to the status of Capacity Assurance Charges for these properties. These charges have been deferred until Mr. Jim Bryson installs an 8" sewer main that will serve the Blue Ridge Estate properties. The owner(s) must contact Tuckaseigee Water & Sewer Authority's office when Mr. Bryson starts and completes the work. At that time a new account will be opened for billing purposes of the Capacity Assurance Charges at the current rate until the project(s) are complete at which time the monthly billing would be changed to flat rate sewer charges(s). If you have any questions please do not hesitate to call me at 828-586-5189 ext. 208. Sincerely, Ald dA-,t� Re ore Billing Specialist Tuckaseigee Water & Sewer Authority Serving Jackson County 1246 West Main Street Sylva, NC 28779 Ph. (828) 586-5189 Fax (828) 631-9089 March 28, 2005 Mr. Peter A. Paul, Attorney at Law PO Box 3049 Cashiers, NC 28717-3049 Subject: Determination of the Gallons per Day assigned to the Hardees Restaurant Property Dear Sir: Please consider the following assessment of daily wastewater treatment capacity as assigned to the former Hardee's restaurant in Cashiers and further identified as Jackson County PIN #7572-21-0616. Given that the restaurant had 45 seats and employed 12 full-time employee equivalents, FTSE, then: 45 seats x 40 gpd/seat + 12 FTEE x 25 gpd/Employee = 2,100 gpd. Should you concur that the above estimate is consistent with our discussion let me know and the gallons per day assigned to this property will accompany information submitted to the TWSA Board of Directors at their April 12'h3 2005 work session in addition to your request for 25,185 gallons of wastewater treatment capacity. Following the discussion and then based on your guidance the request for additional wastewater treatment capacity will be placed on the Regular Meeting Agenda for formal approval and determination of the time frame for which the "Capacity Assurance Fees" would be applicable. Sincerely, Joe Cline Executive Director Cc. Lynda Sossamon, Chairwoman (�""� .son County, NC:: Home in the Mountains Page 1 of l Jackson _ Orth Cstiroli>: a 11 Mar 28, 2005 - o9:01 pM Main Menu Jackson County Real Estate Data • yQme Parcel Summary PIN # 7672-21-0616 Owner Account ID 0 'Public Records Location Address Property Description 'Departments HARDEES ' HARDEES 'Calendar HARDEES Building Land Deeds Tax Cards sr " Stats Property Owner Owner's Mailing Address Property Description • Document Archive BLUE RIDGE EST 3 LLC 6110 N FEDERAL HWY 100 HARi�IES Contact Us LAUDERDALE BY THE SEA ' Employee FL,33308 Calendar rReference istratve Data Transfer Information Assessed Value e p,88 Per Deed Land Value No Events heet 7672,p3 Book/Page 1446/0384 Tot. Bldg. ference Deed Date 2004-08-30 Value Upcoming events Tract 9649 Instrument Type Tot. Out Bldg. undary * Revenue StampVal. No Events ip Cashiers Sale Price 700,000 trict * Additional Ref.Total Qeferred ID 1Value ID 2 Value View Map P r Wj-@ be Version ' Information Not Available Online at This Time DISCLAIMER This information Is for the purpose of Inventory of real property In Jackson County, It is comp recorded deeds, plats, and public data records. Users of this informatlon are hereby notified aforementioned public Information sources should be consulted for verification. Jackson Count employee, representative, or contractor employed by the County assumes no legal responsiblll content of this information or this website. Terms of Use I PrivacyPolicy Hosted by Metrostat.7echnologies, It?c. http://www.jar,lcsonnc.orgl?name=instLandRoll&realni=search&action=parcel suninary&ni.._ 3/9.R/m Aug. 34. 204411:26Ah1, TWSA TUCKA.SEIGEE WATER & SEWER AUTf OPdT'Y APPLICATION FOR SERVICE Application Date: 'S I W 1�- Type of Unit to be Connected: ( Restauraut ( ) Motel No. of Chairs No. of rooms NO. 0031 P. 2 Structure: New( ) Existing 00 ( ) Office No. of Employees ( ) Residential ( } Retail ( ) erAce Station ( ) Single unit Sq. Ft. ( ) Multi units No. of units Location of unit(s) (911 address) to be connected to Name & Address of Occupant i _ ��e± 5N9, iD ND-Fiderril Rip «r 1 ♦ Nance of Previous Occupant Acct. No. 1 1 *A'k-e**********-A ::*A*v4*qtr******icer***icer*** *se **:4: **Ar*** *****; *********************+4* In makiug application for a residential or business water and/or sewer service, I agree to: 1. Pay the impact fee in advance. (if a new service connection) 2. Pay the deposit In advaace. 3. Pay the monthly user fee. 4. Observe all regulations set forth by the Authority. 5. Notify the Authority five working days prior to service date when a new connection is required. Drivers License #53J / Signed: "' f Social Security # 3.30,3 f3312 __ Date: U **"FOR OFFICE USE ONLY**' -k Meter No:Location No: Q—_,yC�) Deposit: 7049007263 THE_OFFICE_LLC_CHARL PAGE 02/03 CASHIERS CANOE CLUB DEVELOPMENT, LLC 1440 S. Tryon Street, Suite 104 Charlotte, NC 28203 OFFICE; (704) 900-7229 FAX: (704) 900-7263 January 5, 2011 VIA. FACSIMILE AND FIRST CLASS MAIL - (828) 631-9089 Ms. Renee' Moore 'Iuckaselgee Water & Sewer Authority 1246 West Main Street Sylva, NC 28779 RE,: Agreement between TWSA and Captiva, Ltd. for 30,600 gallops pee - day capReity (the, "Agreement") pertaining to former Byrd family property Dear Renee'; As you know, Cashiers Canoe Club Development, LLC CICCCD") is the current owner of the property subject to the Agreement and successor to Captiva, Ltd. with regard to the 30,600 gpd reserved sewer capacity. Pursuant to the attached letter dated June 25, 2009, CCCD will begin receiving monthly minimum wastewater bills for the reserved capacity on June 1, 2011. On our recent call, I requested an estimated accounting of the amounts that will be bred our a monthly basis fox our i ntemal budgeting purposes, This letter will serve as CCCD's written request for an accounting of these future charges. Thank you for your prompt attention to this request. 7S' aul J. Smr // Paul-0tbe-office-11c. comp Enclosurc cc: Roseaime Giordmii q )