20180582 Ver 2_USACE Request for More Info_20190529

/j DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
151 PATTON AVENUE
ROOM 208
ASHEVILLE, NORTH CAROLINA 28801-5006
May 29, 2019
Action ID: SAW -2016-00032
C1earWater Environmental Consultants, Inc.
Attn.: Clement Riddle
32 Clayton Road
Asheville, NC 28801
Subject: Corps Request for Additional Information— Cashiers Lake Dredge and Development
Proj ect
Dear Mr. Riddle:
Reference is made to your Department of the Army (DA) permit application (April 2018)
and additional information submitted to the Corps during the Fall 2018 -Spring 2019 for the
Cashiers Lake Dredge and Development Project in Cashiers, Jackson County, North Carolina.
You have submitted this information on behalf of Cashiers Canoe Club Development, LLC.
Based on our review of the submitted additional information, the Corps is requesting additional
information:
1) Submit a draft mitigation plan for review. Due to the potential future improvements along
Frank Allen Road, on-site mitigation areas should exclude a 75 -foot linear corridor along
the south side of this road.
A final mitigation plan must be approved before issuance of a permit. The Corps' mitigation
hierarchy is 1) mitigation thorough purchase of bank credits, 2) mitigation by purchase of
credits with an in -lieu fee program, 3) permittee responsible on-site mitigation, and 4)
permittee responsible off-site mitigation. You are proposing use of blended mitigation (i.e.,
purchase of credits with an in -lieu fee program and permittee responsible on-site
mitigation). Since some of the mitigation is proposed to be provided as permittee
responsible, the mitigation plan must contain the following:
• Statement, with reasons, of why the mitigation requirements cannot be meet by purchase
of credits from a bank or in -lieu fee program.
• Mitigation objective - describe functions lost at impact site, functions to be gained at
mitigation site, and improvements to be gained.
• Site selection criteria - describe process of selecting site, likelihood of success, and future
land use compatibility.

• Site protection instrument - use of the Corps' standard instrument or provide a draft of
proposed legal protective instrument.
• Baseline information - provide a discussion of the ecological characteristics at the
mitigation site and a comparison to the project area; describe historic and existing land
uses; describe aquatic resources impacted; delineate the waters of the U.S. at the
mitigation site based on the issued jurisdictional determination; and describe the site
attributes.
• Credit determination method. Include a table summarizing how credits are to be meet.
• Mitigation work plan - location of the mitigation project area, construction plans, and
describe the planned hydrology, vegetation, soils, buffers, etc., as applicable.
• Maintenance plan - list parties and their responsibilities, and a schedule.
• Ecological performance standards (if applicable) - identify success criteria for soils,
vegetation, and hydrology parameters; outline objectives and verifiable attributes; and
how the standards are to be measured.
• Monitoring requirements (if applicable) - provide a monitoring schedule; identify parties
and responsibilities that will conduct the monitoring; specify data to be collected;
assessment tools and methodologies; and as -built and annual reporting and contents of
reports.
• Long-term management plan - describe long-term financing mechanisms and party
responsible for management.
• Adaptive management plan - identify parties and responsibilities, and describe remedial
measures.
• Financial assurances - identify parties responsible for assurances and specify type of
assurance, contents, and schedule.
2) Submit a revised table summarizing impacts to waters of the U.S. (WoUS).
3) Submit a revised figure depicting impacts to WoUS. Original figure was Stream and
Wetland Impact Map, Figure 3.0.
4) Provide details of the proposed forebay in the northeast portion of the project area. The
details should include location of temporary and permanent access areas.
Please submit comments and the requested additional information by August 31, 2019.
Once the Corps receives the information, a meeting with USFWS, NCWRC, NCDEQ-DWR, and
the Corps may be appropriate in order to review and discuss the information submitted. In order
to aid in the 401 permit process for this project, please copy Sue Homewood and Kevin Mitchell
with NCDEQ-DWR on your documents submitted to the Corps. If you have any questions please
contact me.

Sincerely,
David Brown, PG
Regulatory Specialist/Geologist
Asheville Regulatory Field Office
Copy:
USFWS
Attn.: Byron Hamstead
160 Zillicoa Street
Asheville, NC 28801
NCDEQ-DWR
Attn.: Kevin Mitchell
2090 U.S. Highway 70
Swannanoa, NC 28778
NCDEQ-DWR
Attn.: Sue Homewood
450 W. Hanes Mill Road, Suite 300
Winston Salem, NC 27105
NC WRC
Attn.: Andrea Leslie
645 Fish Hatchery Road
Marion, NC 28752