On September 15th Dominion accepted public comments on its Shoreline Management Plan (SMP). Based on input from our membership over the last several years, the Lake Gaston Association (LGA) made two comments; 1) regarding Appendix E, Aquatic Weed Control revision 5, dated July 10, 2015, and 2) regarding Section 5, Shoreline Management Classifications.
1st Comment: Appendix E, Section 5.2.2 the population of Water willow, Justicia americana, has expanded significantly along Lake Gaston's shoreline. The most recent lake wide Vegetation Survey indicates that Water willow is found on 57% of all survey sites. While we recognize its value in shoreline stabilization, its expanse in some cases has encroached on swimming and water access areas. Currently the SMP does not allow for removal of Water willow under any circumstances. Other native aquatic vegetation is allowed to be removed. Plants outside the boat lane require additional permitting and may only be removed in conjunction with mitigation. We request (in section 5.2.2) that Water willow be added to Table 1, List of native aquatic plants that can be removed, and that the statement "NOTE: Permits will not be issued for the removal of water willow." be removed from the SMP.
Under section 5.3, property owners may then (under permitting) remove Water willow in conjunction with mitigation. All elements of the existing mitigation process remain, but now will include Water willow.
2nd Comment. Section 22.214.171.124 Special Management Areas. Dominion and NCWRC biologists undertook great effort to identify in the field Ecologically Sensitive Areas in 1996 and 1997. Lake Gaston shoreline identified as Ecologically Sensitive (14% or 62.7 miles) and Undevelopable (21% or 102.6 miles) are considered sensitive. Since these areas were identified, development has occurred along adjacent areas (beyond Dominion shoreline property) and clearing has been allowed by permit holders on Dominion’s property. An update or revision to the Sensitive Areas map (dated February 1, 2000) and listing of Ecologically Sensitive Areas (Appendix D) should be completed. Areas should be identified as either Sensitive or Undevelopable/Sensitive.
The SMP allows for different levels of shoreline development in Sensitive Areas. Our concern is that as development has continued, areas which have been identified as Ecologically Sensitive may no longer retain their resource values. A significant “loss” of resource values along the project boundary may indicate that the SMP does not adequately provide environmental protection for these areas. A Sensitive Area update would assist in this determination and guide construction and use procedures in the future. Once Shoreline Management Classifications are updated, Dominion should no longer permit Construction and Use on Sensitive Areas identified as undevelopable. Going forward these sensitive areas should be considered to be protected.