20180612 Ver 2_USACE More Info Requested_20200504

Strickland, Bev
From: Brown, David W CIV USARMY CESAW (USA) < [e-mail] >
Sent: Monday, May 4, 2020 3:17 PM
To: Clement Riddle; Alea Tuttle
Cc: Homewood, Sue; Mitchell, Robert K
Subject: [External] Comments Received to Public Notice - WCU 2014 Master Plan
Improvements Project Request for Permit Modification
Attachments: SAW-2015-00263 WCU 2014 Master Plan Projects Permit Modifcation Request PN
Comments.pdf
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Action ID: SAW-2015-00263
ClearWater Environmental Consultants, Inc.
Clement Riddle and Alea Tuttle,
Attached are the comments the Corps received during the comment period of the public notice for your submitted
request for to modify the permit associated with the WCU 2014 Master Plan Improvements Project in Cullowhee,
Jackson County, North Carolina. You are requested to review the comments and submit to the Corps a document which
responds/addresses the comments/concerns/issues noted. Please submit this document by August 5, 2020. Once the
Corps receives your response, a meeting with NCWRC, NCDEQ-DWR, NCSHPO, and the Corps may be appropriate in
order to review and discuss your submitted response.
As you know, there are significant known cultural resources within the permit area and the project activities, as
proposed, will have direct adverse effect on these resources. The Corps is working through the process with SHPO, the
Eastern Band of the Cherokee Indians, and the Cherokee Nation to mitigate and/or minimize the adverse effect as
required under the Section 106 of the NHPA.
In order to aid in NCDEQ-DWR's 401 permit process for this project, please copy Sue Homewood and Kevin Mitchell with
NCDEQ-DWR on your document to be submitted to the Corps. If you have any questions please contact me.
Thank you,
David Brown, PG
Regulatory Specialist/Geologist
USACE Wilmington District -Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
828-271-7980, ext. 4232
[e-mail]

(UNITED STATES DEPARTMENT OF COMMERCE
y National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
. �e 263 13th Avenue South
BTMres°*°� St. Petersburg, Florida 33701-5505
https:llwww.fisheries.noaa.govlreg ionlsoutheast
(Sent via Electronic Mail) February 12, 2020
Colonel Robert J. Clark, Commander
USACE Wilmington District
69 Darlington Avenue
Wilmington, North Carolina 28403-1398
Dear Colonel Clark:
NOAA's National Marine Fisheries Service (NMFS) reviewed the projects described in the
public notices listed below. Based on the information in the public notices, the proposed projects
would NOT occur in the vicinity of essential fish habitat (EFH) designated by the South Atlantic
Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS.
Present staffing levels preclude further analysis of the proposed work and no further action is
planned. This position is neither supportive of nor in opposition to authorization of the proposed
work.
Notice No. Applicants
Notice Date
SAW-2015-00263 Western Carolina University;
WCU 2014 Master Plan MOD
February 5, 2020
SAW-2015-00401 NCDOT; 174 Improvements
February 10, 2020
SAW-2016-00981 NCDOT; Reedy Fork
Parkway
February 10, 2020
Please note these comments do not satisfy consultation responsibilities under section 7 of the
Endangered Species Act of 1973, as amended. If an activity "may effect" listed species or
critical habitat under the purview of the NMFS, please initiate consultation with the Protected
Resources Division at the letterhead address.
for
Sincerely,
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division
�G � nirrosayFgc
b
s "

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
February 17, 2020
Corps Action ID# SAW-2015-00263
DWR# 20180612 v2
Jackson County
David Brown
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Ave, Room 208
Asheville, North Carolina 28801-5006
Subject Project: Western Carolina University Master Plan Improvements
Dear Mr. Brown:
On behalf of the NC Division of Water Resources, we respectfully request that you consider the following
comments within your review of the 404 Individual Permit request for the above referenced property:
1. The Division recommends that all archaeological fieldwork is finalized and reviewed prior to issuance of
the 404 Individual Permit.
2. The Division recommends that the applicant secure all necessary floodplain development permits prior to
issuance of the 4D4 Individual Permit.
3. The Division has requested additional information from the applicant and requests that the USACE also
consider the attached letter during the review of the application.
Thank you for your considering the Division's comments during your review of this Individual Permit. If you have
any questions, please contact Sue Homewood at 336-776-9693 or [e-mail].
Sincerely,
X11
Mac Haupt, Act igSupervisor
401 & Buffer Permitting Branch
cc: Clement Riddle, ClearWater Environmental Consultants (via email)
DWR ARO 401 files
DWR 401 & Buffer Permitting Unit
�DKQ> North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh. North Carolina 27699-1617
919.707.9000

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

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
March 9, 2020
David Brown, PG
Regulatory Specialist/Geologist
USACE Wilmington District -Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801
Office of Archives and History
Deputy Secretary Kevin Cherry
david.w.brownkusace.army.mil
Re: Stream Impacts for Parking Lot Construction & Intermural Fields Improvements,
Western Carolina University, Cullowhee, Jackson County, ER 18-1185
Dear Mr. Brown:
Thank you for your Public Notice submission of February 5, 2020 and providing us the opportunity to
comment on the above -referenced project. We have reviewed the information provided and offer the following
comments:
As stated in our correspondence, dated February 18, 2020, we concur that there are significant known cultural
resources within the permit area and that the project activities will have direct adverse effects on those
resources. While we recommend avoidance of site 31JK615, if the project proceeds as planned and the adverse
effect cannot be avoided, we look forward to being included in the drafting of a Memorandum of Agreement
between your agency, the US Army Corps of Engineers, and the other consulting and interested parties to
mitigate and/or minimize the adverse effect.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or
environmental.reviewnncdcr.gov. In all future communication concerning this project, please cite the above
referenced tracking number.
Sincerely,
amona Bartos, Deputy
State Historic Preservation Officer
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
February 18, 2020
Office of Archives and History
Deputy Secretary Kevin Cherry
David Brown, PG david.w.brown c&usace.army.mil
Regulatory Specialist/Geologist
USACE Wilmington District -Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801
Re: Stream Impacts for Parking Lot Construction & Intermural Fields Improvements,
Western Carolina University, Cullowhee, Jackson County, ER 18-1185
Dear Mr. Brown:
Thank you for your email of January 21, 2020, providing us the opportunity to comment on the above -referenced
project. We have reviewed the information provided and offer the following comments:
We concur with your conclusion that there are significant known cultural resources within the permit area and that
the project activities will have direct adverse effects on those resources. While we recommend avoidance of site
31JK615, if the project proceeds as planned and the adverse effect cannot be avoided, we look forward to being
included in the drafting of a Memorandum of Agreement between your agency, the US Army Corps of Engineers,
and the other consulting and interested parties to mitigate and/or minimize the adverse effect.
Section 106 of the National Historic Preservation Act, as amended, requires submission of a project with an adverse
effect to be sent to the Advisory Council on Historic Preservation's (ACHP's) using its Electronic Section 106
Documentation Submittal System (e106).
Please note that we concur with the recommendation presented in the interim fieldwork report that data recovery
excavations would be appropriate mitigation.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the Advisory
Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment, contact
Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or environmental.reviewnncdcr.gov. In
all future communication concerning this project, please cite the above referenced tracking number.
Sincerely,
Ramona Bartos, Deputy
State Historic Preservation Officer
cc: Paul Webb, TRC Companies, Inc. pwebb e trccompanies.com
Curtis Monteith, Western Carolina University, [e-mail]
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599