19960052 Ver 2_WRC Comments_20210916

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
September 16, 2021
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Asheville Water Treatment Plant Bank Restoration
Mills River, Henderson County
Dear Mr. Brown,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to stabilize 2,923 ft of the Mills River in Henderson County. NCWRC staff attended
a site visit on September 15, 2021. Our comments on this application are offered for your
consideration under provisions of the Clean Water 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).
Work in the Mills River should not impact trout reproduction, and project activities do not need
to be avoided during the trout spawning moratorium. However, the site is part of the Mills River
Aquatic Habitat, a NC Natural Heritage Program natural area rated Very High due to the richness
of rare species it supports. Species in the vicinity of the project include Appalachian Elktoe
[Alasmidonta raveleniana, US Endangered (E), NC E], Slippershell [Alasmidonta viridis, US
Federal Species of Concern (FSC), NC E], Creeper (Strophitus undulatus, NC Threatened),
Eastern Hellbender [Cryptobranchus alleganiensis, US FSC, NC Special Concern (SC)], and
Blotched Chub (Erimystax insignis, NC SR). NCWRC staff have surveyed the impact area in
the past and have found listed mussels. Excellent sediment and erosion control are essential to
minimize impacts to these important species.
The project involves the construction of toe wood revetments, a boulder toe revetment, bank
sloping, removal of large log jams, removal of non-native vegetation, and planting of native
riparian vegetation. Existing river cane will be transplanted. Work will be done from the river
banks and at low flows and disturbed areas stabilized at the end of each workday.
We appreciate the efforts of the City, the Mills River Partnership, and the designer to address
natural resource concerns.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Asheville WTP Bank Restoration Page 2 September 16, 2021
Mills R, Henderson Co
The planted buffer width is to be at least 150 ft on both sides of the stream on Asheville property.
NCWRC will coordinate with the design team on additional woody species to improve diversity
in the planting plan.
Due to the potential for the project reaches to support listed mussels and hellbenders, NCWRC
and US Fish and Wildlife (USFWS) biologists will survey for and relocate animals this fall and
again before the project begins.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. The applicant should notify Luke Etchison ([e-mail]) and Andrea Leslie
([e-mail]) at least 3 weeks before project construction is to begin so the
affected reaches can be surveyed for mussels and hellbenders and found animals relocated.
2. If at all possible, access to the left bank should be overland, not via a temporary crossing of
the Mills River.
3. Be vigilant with sediment and erosion control during site staging, construction, and cleanup.
We appreciate the plan specification that disturbed areas be `storm -ready' at the end of each
day; this is extremely important at this site.
4. Any erosion control matting used should be free of nylon or plastic mesh, as this type of
mesh netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that
may last for years.
5. If Eastern Hellbenders are disturbed during construction, they should be captured in a bucket
and moved away from the area of disturbance. Contact Lori Williams
([e-mail]) if animals are seen.
6. We ask that a pre -construction meeting be held with the contractor and agency
representatives, including NCWRC.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Kaylie Yankura, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Luke Etchison, and Lori Williams, NCWRC
Zan Price, Jennings Environmental
Maria Wise, Mills River Partnership