20191577 Ver 1_Public Comments_20200331

Strickland, Bev
From: Hartwell Carson <[e-mail]>
Sent: Tuesday, March 31, 2020 9:00 PM
To: SVC_DENR.publiccomments
Cc: Julie Mayfield
Subject: [External] Biltmore Farms LLC
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March 31, 2020
Department of Environmental Quality
401 Permitting
1617 Mail Service Center
Raleigh, NC, 27699-1617
Re: CWA Section 401 Permit Application by Biltmore Farms to construct a bridge across the French
Broad River
Dear DEQ:
Biltmore Farms is proposing to build a five -lane bridge across the French Broad River to serve a new 80+ acre
economic development project along the French Broad River. The proposed bridge is 1000 feet downstream of
the Blue Ridge Parkway bridge across the river and just downstream of Bent Creek Park.
While we do not oppose the bridge or the anticipated development, we are concerned about several aspects of
this project and believe that more could be done to protect the French Broad River, protect nearby endangered
species and their habitat and ensure a safe experience for the many recreational users of this section of the
river. Below are our concerns and recommendations.
Information about the project from the permit application
• Biltmore Farms owns a 445-acre
• wooded parcel next to 1-26, the Blue Ridge Parkway and the French Broad River.
• Logging and grading of 80.5
• acres and grading another 3.3 acres of already cleared land is currently ongoing in preparation for
construction of a 750,000 square -foot facility and 1149 parking spaces. The total anticipated impervious
surface is 41.6 acres.
• Three acres of trees along
• the river will be cleared in order to build the bridge.
• Rock causeways built in
• the river to facilitate bridge construction will extend 80 feet from the west bank and 70 feet from the
east bank and could be in place for up to 12 months.

• 12 columns (or piers) of
• poured concrete will be constructed in the river to create two permanent bridge supports. This
construction will occur within a steel shaft that will be inside the causeways. Drilling for and pouring the
columns will take up to 8 weeks.
• The bridge will be 550 ft.
• long and 5 lanes wide with a bike/pedestrian lane.
• There will be 116 linear
• feet of permanent impact to each bank of the French Broad River as part of the bridge construction.
• The bridge will permanently
• impact .067 acres of wetlands.
• The project documents refer
• to closing the river for up to eight days during construction. The bridge work is anticipated to start in
May.
Concerns and Recommendations
Because of the potential impact of the bridge and this development, as well as possible future development at
this site, the French Broad Riverkeeper cites the following concerns and makes the following recommendations
to minimize the impacts of this project:
• The proposed stormwater
• controls for the facility are wet ponds, which are the minimum required by law and the least effective
way to treat polluted stormwater that washes off parking lots, roofs and other impervious surfaces. In
addition, the discharge from one of these ponds is
• directed toward and could negatively impact a wetland adjacent to the river. Instead of wet ponds, we
recommend using more effective, low -impact development strategies such as rain gardens, grass
swales, pervious pavement, and cisterns. Sierra Nevada and New
• Belgium model two excellent examples of building an industrial facility next to the French Broad River
and using the most effective levels of stormwater management strategies. These companies have set a
new bar for industrial site and facility development
• in Asheville, including both facilities being LEED-certified, and we hope this site and facility can be
developed to meet that bar.
• The causeways and river
• closings could have a major impact on the thousands of paddlers and other river users that access the
French Broad River at Bent Creek River Park. The access at Bent Creek River park is approximately .1
miles upstream of this new bridge and is one of the most

• popular river access points on the entire French Broad River. In order to minimize the impact to
recreational boating, Biltmore Farms should commit to:
0
o Keeping the river open and
o passable throughout construction to the greatest degree possible. When full closures are
necessary for boater safety, such as when the bridge beams are laid across the river, these
closures should be for the minimum time necessary, not during weekends, and
0 outside of the May - September high recreation season.
0
0
o Reducing the length of the
o west bank causeway or, at a minimum, reducing the length of time the entire 80 feet will be in
the river. Blocking the river for 80 feet just .1 mile downstream of a river access point will be a
safety hazard for many boaters. When the river levels are high
o and water is flowing fast, it will be difficult for many inexperienced boaters and tubers to
navigate over to the middle of the channel in order to avoid the large rock causeway.
0
0
o We have also recommended
o that Biltmore Farms meets with outfitters to discuss these plans and receive additional
feedback.
0
• The bridge is proposed in
• the location of a known federally listed endangered species, the Appalachian Elktoe mussel. We also
understand there are documented populations of Appalachian Elktoe downstream of the bridge. The
401 permit should require that these mussels, which are heavily
• impacted by sediment, are not harmed by the construction of the bridge.
• We recommend that the permit
• require Biltmore Farms to partner with the US Geological Survey to install a real-time water quality
monitoring meter downstream of the proposed bridge that would identify water quality problems when
they occur. This would reflect the same commitment that
• NCDOT has taken by installing five water quality monitoring probes to monitor any potential impact
they will have from replacing bridges over the French Broad River during construction of 1-26.
• Explore with Buncombe County
• and the City of Asheville the idea of extending the ART W2 bus line about 1.5 miles from its current
terminus at Ridgefield Boulevard to this new manufacturing site. This would give workers another
commuting option, would reduce the carbon footprint of the
• 1000+ cars per day accessing the site, and would reduce the need for parking and the amount of
impervious surface.

• You have committed to us
• verbally about several issues that we want to recount here.
o First, you have indicated
o you will not be required to cut three acres of trees along the river to meet the no -rise
requirement.
o Second, you have committed
o that no drilling fluid will be used in the drilling process and, therefore, that no drilling fluid
will be stored on the banks of the river.
o Third, you can commit that
o the new sewer line from the facility will not touch the wetlands that it runs near.
o Anything else??
• After this bridge and facility
• are built, Biltmore Farms will still own several hundred adjacent acres of undeveloped land. It is
unclear if or how much of this land will be developed in the future, but any future development could
greatly impact the high quality wetlands and streams onsite
• and water quality in the French Broad River. Some of the wetlands on this remaining land are habitat
for rare or listed species including the Bog Turtle, Mole Salamander and Gray Bat. To ensure the long-
term protection of these species and their habitat, we
• recommend placing these wetlands and a large buffer into a conservation easement. We have also
suggested that Biltmore Farms allow the NC Wildlife Resources Commission staff access to survey
these wetlands for the presence of these species.
We realize that most of these recommendations cannot be incorporated into the DEQ-issued 401 permit, but
we relay them here in an effort to ensure that this project attains high standards for environmental protection.
We have discussed these concerns and recommendations with Biltmore Farms and look forward to additional
discussions as the project moves forward.
Sincerely,
Hartwell Carson
French Broad Riverkeeper
T Biltmore Farms comment letter - Final [docs.google.com]