20180612 Ver 2_WRC Comments_20200220

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
February 20, 2020
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Western Carolina University 2014 Master Plan Improvements - Modification
Wetlands, Jackson County
SAW-2015-00263
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the
individual 404 permit application modification for Western Carolina University (WCU) 2014
Master Plan Improvements project, which would impact an additional 0.35 acre in the Cullowhee
Creek floodplain in Jackson County. NCWRC attended a site visit on October 30, 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).
The original permit application was to allow WCU to construct a parking lot, culverting 500 ft of
UT Cullowhee Creek and filling 0.293 acre of wetland, and improve its existing soccer field,
filling 0.09 acre of wetland. This permit modification proposes to impact an additional 0.35 acre
of wetland in order to construct a parking lot and athletic fields.
Project activities should not impact wild trout reproduction, and a moratorium is not needed.
However, Cullowhee Creek is part of the Tuckasegee River Aquatic Habitat, a natural area rated
Exceptional by the NC Natural Heritage Program due to the richness of rare species it contains.
Near the project, Cullowhee Creek and the Tuckasegee River support a number of listed and rare
aquatic species, including the Sicklefin Redhorse (Moxostoma sp., US Candidate, NC
Threatened), Wavy -rayed Lampmussel [Lampsilis fasciola, NC Special Concern), and French
Broad River Crayfish (Cambay us reburrus, US Federal Species of Concern, NC Significantly
Rare).
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

WCU 2014 Master Plan Permit Mod Page 2 February 20, 2020
Wetland on Cullowhee Cr, Jackson County
We offer the following comments and recommendations on this project:
It is extremely important that excellent erosion and sediment control be used during site
staging, construction, and cleanup to protect Cullowhee Creek and Tuckasegee River.
■ To protect the rare and listed species in the Tuckasegee River, we request the use of
sediment and erosion control practices outlined in the Design Standards in Sensitive
Watersheds (15A NCAC 4B .0124). In addition, 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.
■ Matting used on site should be free of nylon or plastic mesh; this type of mesh netting
frequently entangles wildlife and is slow to degrade, resulting in a hazard lasting for
years.
A mitigation ratio of 1:1 is proposed for wetland impacts. NCWAM scores for the wetlands
were Low. The proposed wetland impacts are especially concerning due to their proximity to
the Tuckasegee River and their location in the floodplain of Cullowhee Creek; and NCWRC
recommends that a higher ratio of 2:1 be used for wetland impacts for this project.
Effective stormwater management is essential in minimizing impacts to downstream waters.
Stormwater control measures should mimic the hydrograph consistent with an impervious
coverage of less than 10%. 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.
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 Consultants
Amy Annino & Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service