HomeMy WebLinkAbout20180582 Ver 2_Response to Chattooga Conser and Public Comments_20190418Staff Review
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20180582
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Reviewer List:* Kevin Mitchell:eads\rkmitchell
Select Reviewing Office:* Asheville Regional Office - (828) 296-4500
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Project Contact Information
Name: Kaylie Yankura
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Email Address: kaylie@cwenv.com
Project Information
Existing ID #: Existing Version:
20180582 1
20170001 (no dashes)
Project Name: Cashiers Canoe Club Development
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r No
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Jackson
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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
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• Document Archive BLUE RIDGE EST 3 LLC 6110 N FEDERAL HWY 100 HARi�IES
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' 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
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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 )