20180582 Ver 2_Request for more info_20190603

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
June 3, 2019
DWR # 20180582 V2
Jackson County
Cashiers Canoe Club Development, LLC
Attn: Roseanne Giordani
PO Box 300849
Austin, TX 78703
Subject: REQUEST FOR ADDITIONAL INFORMATION
Cashiers Canoe Club Development and Lake Dredging
Dear Ms. Giordani:
On April 12, 2019, the Division of Water Resources — Water Quality Programs (Division) received your re-
application dated April 12, 2019, requesting a 401 Individual Water Quality Certification from the
Division for your project. Please reference your application dated April 24, 2018 and previous
correspondence between the Division and your consultant, ClearWater Environmental Consultants Inc.
The Division has determined that your application is still incomplete and cannot be processed. The
application is on -hold until all of the following information is received:
1. Additional information on the permanent forebay maintenance access
The response below is from an email correspondence submitted by ClearWater Environmental
Consultants dated April 12, 2019:
The application has been revised to include information about the forebay, including
wetland impacts associated with forebay construction. These impacts have been included
on the Stream & Wetland Impact Map, Figure 3 (Attached, revised April 12,
2019). Wetland impacts related to the forebay construction laydown yard and permanent
forebay access and maintenance have also been updated on Figure 3. Forebay wetland
impacts include:
i. 0.21 acre of wetland impact for fill associated with forebay construction.
ii. 0.36 acre of wetland impact associated with the proposed forebay laydown yard and permanent
maintenance access.
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
Moana GwauNn �
919.707.9000

Cashiers Canoe Club Development, LLC
DWR# 20180582 v2
Request for Additional Information
Page 2 of 3
In order to document avoidance and minimization, please provide more information regarding the
minimum requirements (size and/or alignment/access) for the permanent forebay maintenance
access.
2. Downstream flows
The response below is from an email correspondence submitted by ClearWater Environmental
Consultants dated April 12, 2019:
The proposed 0.5 CFS matches the previously approved and permitted plans pertaining to dam
maintenance and improvements from 2009 when the lake was drained. Inflow and outflow will be
measured by flow meters upstream at the Frank Allen culvert and downstream of the dam.
The North Carolina Wildlife Resource Commission has requested that the minimum downstream flow be
maintained at 70% of inflow to protect downstream aquatic habitat. Previous permitting actions are not
considered an adequate justification for approval of an alternative minimum release flow at this time.
Please note that the Division will include a requirement for a minimum release flow of 70% of the
inflow, as measured by the proposed inflow and outflow meters, unless you provide additional
justification and supportive evidence for an alternative minimum flow release.
3. ORW stormwater requirements
The response below is from an email correspondence submitted by ClearWater Environmental
Consultants dated April 12, 2019:
Please reference Sheet C2-00 of the revised Cashiers Lake Dredging Plan (submitted by CEC on April
12, 2019 with the "Request to Re -Apply for 401 Water Quality Certification" letter). DWQ approved
the stormwater plans for a portion of the proposed residential development, labeled as DA #1, on
May 14, 2009. The proposed hotel has been eliminated from the project, and the residential
development identified as DA #2 is planned in its place. This residential area is subject to ORW
stormwater rules. The Applicant will submit a stormwater treatment final design pending issuance
of the 401 Water Quality Certification. The proposed stormwater practice will be similar to the
already approved DA #1.
A comparison of the proposed overall master plan and the approved stormwater plan from 2009
indicates modifications to the development design. The Division requires that you submit a permit
modification request to DEMLR for DA#1 to ensure that the current project design meets ORW
Stormwater Requirements.
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested
information for the proper consideration of the application. Please respond in writing within 30
calendar days of receipt of this letter by sending one (1) copy of all of the above requested information

Cashiers Canoe Club Development, LLC
DWR# 20180582 v2
Request for Additional Information
Page 3 of 3
to the 401 & Buffer Permitting Branch, 1617 Mail Service Center, Raleigh, NC 27699-1617 OR by
submitting all of the above requested information through this
link: https://edocs.deg.nc.gov/Forms/Supplemental-Information-Form (note the DWR# requested on
the link is referenced above).
If all of the requested information is not received within 30 calendar days of receipt of this letter, the
Division will be unable to approve the application and it will be returned. The return of this project will
necessitate reapplication to the Division for approval, including a complete application package and the
appropriate fee.
Please be aware that you have no authorization under the Water Quality Certification Rules for this
activity and any work done within waters of the state may be a violation of North Carolina General
Statutes and Administrative Code.
Please contact me at 336-776-9693 or Sue. [e-mail] if you have any questions or
concerns.
Sincerely,
DocuSigned by:
466ED631098F411...
Sue Homewood
DWR Winston Salem Regional Office
cc: Kaylie Yankura, ClearWater Environmental Consultants Inc. (via email)
David Brown, USACE Asheville Regulatory Field Office (via email)
Andrea Leslie, NCWRC (via email)
Byron Hamstead, USFS (via email)
DWR ARO 401 files
DWR 401 & Buffer Permitting Unit