20181446 Ver 1_WRCComments_20181211

9 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
December 11, 2018
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: City of Asheville North Fork Water Line Project
North Fork Swannanoa River, UT, and wetlands, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to impact 5 wetlands, entailing 0.17 acre of permanent and 0.29 acre of temporary
impacts, and impact 2 stream sites, entailing 105 ft of temporary impact on the North Fork
Swannanoa River and an unnamed tributary (UT), all for a water line project in Buncombe County.
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).
Project activities will not impact wild trout, and project activities do not need to be avoided during a
trout moratorium.
The construction corridor will be 45 ft wide, and a permanently maintained right-of-way (ROW) will
be 20 ft wide in stream and wetland areas and 24 ft wide in upland areas. The water line will parallel
the North Fork of the Swannanoa River for 1,290 ft, and in some locations, it is perhaps 10 ft from
the river bank. We recommend that the ROW be narrowed to 20 ft where it is within 30 ft of the
river. We also ask that the City plant native woody species within the construction corridor that will
not be permanent ROW that is within 30 ft of the North Fork of the Swannanoa River. In addition,
we ask that the City plant the permanent ROW that is parallel to the river in native riparian seed mix.
The water line will be installed though wetlands and streams with the trench cut method. Trench cuts
through streams will be performed in the dry. Riprap would be used in the bed and on the banks of
the North Fork Swannanoa River at the site of trenching in order to ensure stability, as flows within
the river are extremely variable, dependent on reservoir releases. We recommend the use of
livestakes in addition to riprap on the banks.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

North Fork Water Line Page 2 December 11, 2018
N. Fork Swannanoa, Buncombe Co
Wetland top soils will be stored and replaced as top soil within the trenches that run through
wetlands. All wetland work will be performed from wetland mats. Native wetland seed mix will be
used in disturbed wetland areas. Mitigation of 1:1 is proposed for permanent impacts to wetlands,
which consist of shifting wetlands from forested to herbaceous. In wetland areas, we recommend
that the applicant mark the construction corridor clearly in the wetland, fencing/taping the non-
impact area and ensuring construction equipment will be kept out of this area.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Avoid equipment maintenance in the immediate vicinity of streams and wetlands, make stream
crossings as narrow as possible, minimize stream bank disturbance, avoid spraying of herbicides,
and where woody vegetation is cleared, cut so that stumps can resprout.
2. Sediment and erosion controls measures should be installed prior to any land clearing or
construction. These measures should be routinely inspected and properly maintained. Excessive
silt and sediment loads can have numerous detrimental effects on aquatic resources including
destruction of spawning habitat, suffocation of eggs, and clogging of gills of aquatic species.
3. For forested wetlands, any area outside the maintenance right-of-way (ROW) should be replanted
with native woody species.
4. Within wetlands, mark the construction corridor clearly in the wetland, fencing/taping the non-
impact area and ensuring construction equipment will be kept out of this area.
5. For the UT to the North Fork Swannanoa River, the top 6-12 inches of stream substrate should be
stockpiled, kept saturated during pipe installation, and replaced once the pipe is installed.
6. We recommend that the native riparian mix be applied within the permanent ROW that parallels
the North Fork Swannanoa River.
7. We recommend that the ROW be narrowed to 20 ft where it is within 30 ft of the river. We also
ask that the City plant native woody species within the construction corridor that will not be
permanent ROW that is within 30 ft of the North Fork of the Swannanoa River.
8. Matting used for stabilization should be free of nylon or plastic mesh, as this type of netting
frequently entangles wildlife and is slow to degrade resulting in a hazard that may last for years.
9. ROW maintenance on stream banks should be performed by hand, cutting woody vegetation to
allow resprouting. ROW maintenance through wetlands should also be done by hand, avoiding
the use of heavy machinery. If heavy machinery is used in wetlands, wetland mats should be
used.
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,
�o�zd-Cx�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Jon Swaim, McGill Associates
Zan Price, NC Division of Water Resources
Allen Ratzlaff, US Fish and Wildlife Service