20191755 Ver 1_WRC Comments_20200131

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
January 31, 2020
Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Project Ranger
French Broad River and Wetland, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to fill 0.07 acre of wetland, temporarily impact 138 ft (0.67 acres) of the French
Broad River, and permanently impact 139 ft of the French Broad River for the construction of a
bridge to access land for development in Buncombe County. NCWRC staff visited the site on
November 7, 2019. 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). These comments are based
on information about the project received with the Pre -construction Notification received on
11/13/2019, revised plan documents and email dated 1/6/2020, and a draft Biological
Assessment dated 1/16/2020.
Project activities should not impact wild trout and do not need to be avoided during a trout
moratorium. However, the French Broad River at this location supports Appalachian Elktoe
(Alasmidonta raveneliana, US & NC Endangered), Creeper [Strophitus undulatus, NC
Threatened (T)], and possibly Eastern Hellbender [Cryptobranchus alleganiensis, US Federal
Species of Concern, NC SC (Special Concern)]. Gray Bat (Myotis grisescens, US & NC
Endangered) is found in the project area, and Northern Long-eared Bat (Myotis septentrionalis,
US & NC Threatened), Bog Turtle (Glyptemys muhlenbergii, US Threatened due to Similarity of
Appearance, NC T), and Mudpuppy (Necturus maculosus, NC SC) may occur in the project
vicinity. The French Broad River supports a Muskellunge (Esox masquinongy), Smallmouth
Bass (Micropterus dolomieu), and Redbreast (Lepomis auritus) fishery, and NCWRC is
beginning a 5-year Muskellunge population study. Activities involved with this project have the
potential to directly and indirectly impact these species, and we provide a number of
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Project Ranger Page 2 January 31, 2020
French Broad R & wetland, Buncombe Co
recommendations to minimize these impacts as well as conserve or create habitat for these
species.
The project involves the construction of a 610-ft long 5-lane bridge across the French Broad
River, approximately 1000 ft downstream of the Blue Ridge Parkway bridge. This new bridge
will lead to a road that will be constructed to access an industrial site. Total limits of disturbance
are estimated to be 84 acres, with 80 acres of tree clearing. Components of this project include
the following:
• The bridge would have two bents, with 5 pilings each, and allow 20-30 ft of clearance above
the water surface. Installation of the bridge footings will involve drilling in the riverbed, and
bent installation may require pile -driving. In order to construct the bridge, temporary rock
causeways of Class II riprap would be constructed along both banks of the river in two
phases. Phase 1 would involve dual 114 ft causeways running parallel to river flows,
extending 80 and 70 ft into the river from the west and east banks, respectively, and filling
0.34 acre for 12 months. Phase 2 would extend the Phase 1 causeways by 24 ft in length
(parallel to flows) and 40 ft in width (each). Phase 1 causeways would be in place for 12
months, and Phase 2 causeways would be in place for 1 month of that time. During Phase 1,
37% of the river width will be blocked, but during Phase 2, 64% of the river will be blocked.
A river safety plan to warn approaching river users has been developed.
• In order to comply with Federal Emergency Management Agency no -rise requirements, the
applicant proposes to clear riparian forest along 270 ft (1.3 acres) of the west bank and 260 ft
(1.7 acres) of the east bank. It is unknown if any of this area will also be excavated, and if
so, if what means will be used to stabilize the area. An additional 3 acres of trees will be
cleared in the vicinity of the bridge to accommodate excavation and bridge construction.
Excavation will not extend to the water's edge. Banks would be stabilized with riprap along
114 ft under the bridge. Tree clearing will be avoided during the bat maternity season of
May 15 to August 15.
• Drainage from the bridge would be directed west to grated inlets installed off the bridge and
discharged onto riprap dissipater pads at least 50 ft from the river. It is possible that a deck
drain system will be used to reduce stormwater spread on the bridge, and this would be
discharged on riprap dissipater pads at least 30 ft from the river. After leaving pads,
stormwater would be dispersed as sheet flow and infiltrate through vegetated areas.
• 0.067 acre of wetland would be impacted for bridge construction.
• The bridge would connect NC 191 with a new road on Biltmore Farms property. This road
would be cleared and graded to accommodate a four -lane road, with only a two-lane road
being constructed initially.
• The road would lead to an industrial facility that will be approximately 750,000 fe (17.2
acres) with possible future expansion areas, which will be cleared and graded in association
with the initial phase of work. Parking for approximately 1,200 employees will be provided,
with 617 parking spaces provided initially; future parking is proposed to include another 532
spaces. Blasting (60 total blasts) may occur for site development for approximately 6
months.
• Old River Road on the Biltmore Farms property will be used to access the construction area
from Schenk Road, and an additional gravel road that crosses under the Blue Ridge Parkway
would also be used. The footprint of the roads will not be widened, but trees may be cleared
along the edges of the road to facilitate equipment movement. Existing culverts will not be
lengthened.

Project Ranger Page 3 January 31, 2020
French Broad R & wetland, Buncombe Co
• The proposed impervious area will be 41.6 acres for the manufacturing facility and parking
areas, bridge, access road and round -about, including future expansion areas. The 445-acre
tract will be 9% impervious.
• Sediment and erosion control measures will be designed for the 25-year storm. Permanent
post -construction stormwater management will treat the 1-year 24-hour storm event, and the
rate of discharge will not exceed the pre -development rate for this storm event. Two
stormwater ponds will be built at the development site, with outlets directed away from
wetlands. Velocity control measures will be designed to limit scour and erosion at the pond
outlets.
The applicant is working with US Fish and Wildlife Service (USFWS) through the Biological
Assessment process. Conservation measures are in development to avoid/minimize effects and
to partially offset anticipated effects to federally listed species, particularly Gray Bat, Northern
Long-eared Bat, Bog Turtle, and Appalachian Elktoe. Among the conservation measures being
discussed are construction specifications to limit percussive and light impacts to bats, permanent
lighting specifications, erosion control specifications, bat roost paneling and monitoring on the
new bridge, and conservation funding for Appalachian Elktoe.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Work should be accomplished as quickly as possible and vigilance used in sediment and
erosion control during site preparation, construction, and clean up. Due to the presence of
listed species in the French Broad River, we ask that disturbed areas be stabilized on a tight
timeframe to minimize risk of sediment loss, namely, the disturbed areas should be seeded,
mulched and/or matted as soon as possible, preferably at the end of each work day; at a
minimum, disturbed areas should be stabilized within five working days or seven calendar
days, whichever is shorter. This tighter stabilization timeframe is of particular importance in
riparian areas and along stream banks.
2. Seeding specifications have not been provided. Seeding mixes should not include invasive
species, such as Tall Fescue and Sericea Lespedeza. Permanent seed mixes should be
comprised of native grasses and forbs. An emphasis on pollinator -beneficial species should
be made.
3. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
mesh netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that
may last for years.
4. We request detailed information (including maps) on the area of riparian clearing and
excavation, as well as information on how excavated areas will be stabilized.
5. Drilling within the riverbed involves a risk of frac-out. We request that the applicant develop
a frac-out contingency and containment plan.
6. Effective stormwater management is essential in minimizing impacts to downstream waters.
Instead of the stormwater management measures proposed (two large ponds), we recommend
the use of Low Impact Design techniques, such as grassed swales and pervious pavement;
curb and gutter, catch basins, and underground piping of stormwater should be avoided. As
stormwater runoff from pavement can cause short-term temperature spikes in downstream
waters, mechanisms to lower stormwater temperature should be incorporated into the
stormwater management design.

Project Ranger Page 4 January 31, 2020
French Broad R & wetland, Buncombe Co
7. We are concerned about the erosive capacity of stormwater from the bridge and the
development. Although velocity control measures will be designed to limit scour and erosion
at the pond outlets at the industrial site, we are concerned about scour and erosion
downstream of the pond outlets and ask the applicant to provide additional details as to how
this will be avoided.
8. We request that NCWRC and USFWS biologists be allowed on the Biltmore Farms site in
order to monitor rare and listed species, in particular bog turtles, gray bats, listed
salamanders, and birds. We recommend that Biltmore Farms, NCWRC, and USFWS
develop an agreement to allow periodic and long-term access to the site.
9. There are several large wetlands within the larger French Broad River floodplain on the
Biltmore Farms site that provide habitat for Bog Turtle, Mole Salamanders, and other rare
and/or listed species. We strongly recommend that conservation easements be established on
these ecologically important sites.
10. We support the discussions being held between the USFWS and the applicant to develop
conservation measures to minimize impacts to and benefit the Gray Bat. We appreciate the
applicant's willingness to install bat panels, support monitoring of bat populations during the
project, limit percussive activities, and minimize light pollution within the river corridor and
at the industrial area.
11. The project will eliminate riparian habitat along almost 300 ft of the French Broad River.
Riparian forest is important in maintaining bank stability, treating surface water pollutants,
slowing flood stage flows, moderating river temperature, and providing in -stream habitat.
For the Gray Bat, this forested riparian area is also an important habitat, as gray bats fly
along river banks within the shelter of the trees. We ask that riparian clearing be minimized
as much as possible and large trees along the river's edge be left to retain some habitat for
bats and provide some of the functions of riparian habitat.
12. If possible, any in -channel work should avoid disturbing large flat rock that could serve as
hellbender shelters.
13. We ask that the applicant notify NCWRC biologists Lori Williams
(lori.williams(abncwildlife.org) and Luke Etchison(luke.etchison(ii)ncwildlife.org) at least 2
weeks before any in -channel work begins.
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: Clement Riddle, C1earWater Environmental
Mary Frazier, Three Oaks Engineering
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Katherine Etchison, Luke Etchison, Gabrielle Graeter, Scott Lofits, Kendrick Weeks, and
Lori Williams, NCWRC