20200705 Ver 1_More Info Received_20200817

Strickland, Bev
From:
Tyson Kurtz <[e-mail]>
Sent:
Monday, August 17, 2020 1:41 PM
To:
Fuemmeler, Amanda J CIV (US)
Cc:
Homewood, Sue; Clement Riddle
Subject:
[External] RE: ASU Child Care PCN AID 2020-00959 Request for additional information
Attachments:
NC SAM S2.pdf
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Amanda,
Please see the responses to your request for additional information below. The project was on a temporary hold
while the university worked out zoning requirements with Boone.
1. Please provide information as to why a second access/road crossing is needed for the facilities expansion and will
this crossing/area provide parking as well. It is also unclear from the plans the need to fill the entire length of the
stream channel versus just have a more narrow road crossing with retaining walls. Please discuss if retaining
walls could be used which would minimize impacts to the stream channel.
A. The secondary access/road crossing is needed for the facilities expansion and will provide parking. The
expansion needs to be placed adjacent to the existing building (explained under question 2A), the proposed
location would be built on the existing upper parking area. This would create a loss of about 10 parking
spaces close to the front doors while simultaneously increasing the need for proximal parking spaces.
Available parking close to the front doors is required for families with infants. Expanding the existing lower
parking lot and incorporating parking spaces in the new drive loop/second access road is the most efficient
option. The existing upper parking area is already abutting the stream; therefore, new parking in front of the
buildings would have to be pushed northward, over top of the stream. The drive loop/secondary access
would allow for ease of daily children drop-off and pick-up. The drive loop/secondary access would also
allow for fire truck access to both buildings.
B. The engineer investigated an alternative that would reduce stream impacts to less than 149 linear feet and
the results did not provide a benefit to the overall project cost or stream quality. A spanning arch pipe
structure could avoid 90 feet of stream bed at a cost of approximately $83,700 without considering
additional costs to the existing stormwater system and logistics of construction. If a 90 feet long arch pipe
was used, the remaining 59 feet of stream in the impact area would still need to be placed into a culvert.
C. The use of retaining walls to minimize impacts to the stream channel is not considered a practicable option
with the grade of the stream valley and location of the stream bed adjacent to a potential vertical wall
foundation. Even with retaining walls, it is not possible to create a stable slope inside the drive loop or on
the upslope side of the road crossing that would avoid impacting the stream channel. Examples of retaining
walls of this nature have been shown to be very unstable, limit access for maintenance, and create a danger
to young children, for which the facility is designed.
2. Also please address why other portions of the parcel that are currently open/not developed could not be used for
the facility which have existing pipes/culverts and would not require much if any additional stream piping.

A. Building the Child Development Expansion adjacent to the existing building allows for students from both
buildings to share the playground and facilitates resource sharing for faculty and students. The grade
difference and distance between the existing building and the lower field area (alternate location in
question) would require children crossing traffic and parking areas, which is a safety hazard.
B. Construction of the building along the southwest side of the existing building requires less grading and
clearing when compared to other sides of the existing building that have enough space. The proposed
location is mostly clear of trees and is partially at grade.
C. The location of underground and overhead utilities in lower field make the alternative building location less
suitable and more expensive than the proposed location.
D. Limited space on the lower field (alternate location) would require the new building to be situated close to
Poplar Grove Road. Having a childcare facility that close to the road raises issues of noise and safety for
child.
Attached is the NC Stream Assessment Method (NCSAM) that was conducted for reach of S2 where impacts have been
proposed. The overall functional score for this reach is medium. Detractors of functional value include altered riparian
structure, width, and lack of woody vegetation; alterations to the banks that reduce streamside area interaction;
impervious surfaces within the streamside area that accelerate runoff, and degraded stream shading. A mitigation ratio
of 1.5:1 is requested based upon the medium functional rating generating by NCSAM.
Thank You,
Tyson Kurtz
CLearWaLer
32 Clayton Street
Asheville, NC 28801
Office: 828-698-9800
Mobile: [phone]
tyson(cDcwenv.com
WWW.CWENV.COM
From: Fuemmeler, Amanda J CIV (US) <[e-mail]>
Sent: Wednesday, June 24, 2020 5:11 PM
To: Tyson Kurtz <[e-mail]>
Cc: Homewood, Sue <[e-mail]>; Clement Riddle <[e-mail]>
Subject: ASU Child Care PCN AID 2020-00959 Request for additional information
Tyson,
Thanks for meeting out the other day. As discussed, I had several questions relating to avoidance and minimization
efforts on the design that was included in the PCN which I've outlined below. Also we discussed mitigation requirements
in relation to past impacts which just on this parcel alone appear to be at least 200-300 linear feet of perennial stream
channel that has been culverted at some point in the past. So with that said, any additional stream impacts at this point
would trigger mitigation and a mitigation plan should be submitted with the PCN that adequately offsets impacts.
Mitigation ratios typically start at 2:1 unless you conduct NCSAM and depending on the results, potentially a reduced
ratio can be applied. With regards to avoid/minimization, please provide additional information/ clarification on the
following to continue the review of this application:
1. Please provide information as to why a second access/road crossing is needed for the facilities expansion and
will this crossing/area provide parking as well. It is also unclear from the plans the need to fill the entire length
of the stream channel versus just have a more narrow road crossing with retaining walls. Please discuss if
retaining walls could be used which would minimize impacts to the stream channel.

2. Also please address why other portions of the parcel that are currently open/not developed could not be used
for the facility which have existing pipes/culverts and would not require much if any additional stream piping.
Once I receive this information, I will review and provide follow up questions/comments as needed. Feel free to give me
a call with any questions, thanks.
Amanda Jones
Regulatory Specialist
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
828-271-7980 ext. 4225

USACE AID #:NCDWR #:
PROJECT / SITE INFORMATION:
1. Project name (if any):2. Date of evaluation:
3. Applicant/owner name:
5. County:6. Nearest named water body
7. River Basin: on USGS 7.5-minute quad:
8. Site coordinates (decimal degrees, at lower end of assessment reach):
STREAM INFORMATION: (depth and width can be approximations)
9. Site number (show on attached map):10. Length of assessment reach evaluated (feet):
11. Channel depth from bed (in riffle, if present) to top of bank (feet):Unable to assess channel depth.
12. Channel width at top of bank (feet):13. Is assessment reach a swamp stream?Yes No
14. Feature type:Perennial flow Intermittent flow Tidal Marsh Stream
STREAM RATING INFORMATION:
15. NC SAM Zone:Mountains (M)Piedmont (P)Inner Coastal Plain (I)Outer Coastal Plain (O)
16. Estimated geomorphic
valley shape (skip for a b
Tidal Marsh Stream):(more sinuous stream, flatter valley slope)(less sinuous stream, steeper valley slope)
17. Watershed size: (skip Size 1 (< 0.1 mi2)Size 2 (0.1 to < 0.5 mi2)Size 3 (0.5 to < 5 mi2)Size 4 (≥ 5 mi2)
for Tidal Marsh Stream)
ADDITIONAL INFORMATION:
18. Were regulatory considerations evaluated?Yes No If Yes, check all that appy to the assessment area.
Section 10 water Classified Trout Waters Water Supply Watershed (I II III IV V)
Essential Fish Habitat Primary Nursery Area High Quality Waters/Outstanding Resource Waters
Publicly owned property NCDWR riparian buffer rule in effect Nutrient Sensitive Waters
Anadromous fish 303(d) List CAMA Area of Environmental Concern (AEC)
Documented presence of a federal and/or state listed protected species within the assessment area.
List species:
Designated Critical Habitat (list species):
19. Are additional stream information/supplementary measurements included in "Notes/Sketch" section or attached?Yes No
1.Channel Water – assessment reach metric (skip for Size 1 streams and Tidal Marsh Streams)
A Water throughout assessment reach.
B No flow, water in pools only.
C No water in assessment reach.
2.Evidence of Flow Restriction – assessment reach metric
A At least 10% of assessment reach in-stream habitat or riffle-pool sequence is adversely affected by a flow restriction or fill to the
point of obstructing flow or a channel choked with aquatic macrophytes or ponded water or impounded on flood or ebb within
the assessment reach (examples: undersized or perched culverts, causeways that constrict the channel, tidal gates).
B Not A
3.Feature Pattern – assessment reach metric
A A majority of the assessment reach has altered pattern (examples: straightening, modification above or below culvert).
B Not A.
4.Feature Longitudinal Profile – assessment reach metric
A Majority of assessment reach has a substantially altered stream profile (examples: channel down-cutting, existing damming,
over widening, active aggradation, dredging, and excavation where appropriate channel profile has not reformed from any of
these disturbances).
B Not A
5.Signs of Active Instability – assessment reach metric
Consider only current instability, not past events from which the stream has currently recovered. Examples of instability include
active bank failure, active channel down-cutting (head-cut), active widening, and artificial hardening (such as concrete, gabion, rip-rap).
A < 10% of channel unstable
B 10 to 25% of channel unstable
C > 25% of channel unstable
6.Streamside Area Interaction – streamside area metric
Consider for the Left Bank (LB) and the Right Bank (RB).
LB RB
A A Little or no evidence of conditions that adversely affect reference interaction
B B Moderate evidence of conditions (examples: berms, levees, down-cutting, aggradation, dredging) that adversely affect
reference interaction (examples: limited streamside area access, disruption of flood flows through streamside area,
leaky or intermittent bulkheads, causeways with floodplain constriction, minor ditching [including mosquito ditching])
C C Extensive evidence of conditions that adversely affect reference interaction (little to no floodplain/intertidal zone access
[examples: causeways with floodplain and channel constriction, bulkheads, retaining walls, fill, stream incision,
disruption of flood flows through streamside area] or too much floodplain/intertidal zone access [examples:
impoundments, intensive mosquito ditching]) or floodplain/intertidal zone unnaturally absent or assessment reach is a
man-made feature on an interstream divide
7.Water Quality Stressors – assessment reach/intertidal zone metric
6"
3'
NC SAM FIELD ASSESSMENT FORM
Accompanies User Manual Version 2.1
INSTRUCTIONS:Attach a sketch of the assessment area and photographs.Attach a copy of the USGS 7.5-minute topographic
quadrangle,and circle the location of the stream reach under evaluation.If multiple stream reaches will be evaluated on the same
property,identify and number all reaches on the attached map,and include a separate form for each reach.See the NC SAM User
Manual for detailed descriptions and explanations of requested information. Record in the "Notes/Sketch" section if any supplementary
NOTE EVIDENCE OF STRESSORS AFFECTING THE ASSESSMENT AREA (do not need to be within the assessment area).
measurements were performed. See the NC SAM User Manual for examples of additional measurements that may be relevant.
ASU Child Care March 30, 2020
36.216960, -81.691960
S2 200
Appalachian State University 4. Assessor name/organization:ClearWater Env. Consultants
Watauga
New Boone Creek
Check all that apply.
A Discolored water in stream or intertidal zone (milky white, blue, unnatural water discoloration, oil sheen, stream foam)
B Excessive sedimentation (burying of stream features or intertidal zone)
C Noticeable evidence of pollutant discharges entering the assessment reach and causing a water quality problem
D Odor (not including natural sulfide odors)
E Current published or collected data indicating degraded water quality in the assessment reach. Cite source in the "Notes/Sketch"
section.
F Livestock with access to stream or intertidal zone
G Excessive algae in stream or intertidal zone
H Degraded marsh vegetation in the intertidal zone (removal, burning, regular mowing, destruction, etc.)
I Other:(explain in "Notes/Sketch" section)
J Little to no stressors
8.Recent Weather – watershed metric
For Size 1 or 2 streams, D1 drought or higher is considered a drought; for Size 3 or 4 streams, D2 drought or higher is considered a
drought.
A Drought conditions and no rainfall or rainfall not exceeding 1 inch within the last 48 hours
B Drought conditions and rainfall exceeding 1 inch within the last 48 hours
C No drought conditions
9 Large or Dangerous Stream – assessment reach metric
Yes No Is stream is too large or dangerous to assess? If Yes, skip to Metric 13 (Streamside Area Ground Surface Condition).
10.Natural In-stream Habitat Types – assessment reach metric
10a.Yes No Degraded in-stream habitat over majority of the assessment reach (examples of stressors include excessive
sedimentation, mining, excavation, in-stream hardening [for example, rip-rap], recent dredging, and snagging)
(evaluate for size 4 Coastal Plain streams only, then skip to Metric 12)
10b.Check all that occur (occurs if > 5% coverage of assessment reach) (skip for Size 4 Coastal Plain streams)
A Multiple aquatic macrophytes and aquatic mosses F 5% oysters or other natural hard bottoms
(include liverworts, lichens, and algal mats)G Submerged aquatic vegetation
B Multiple sticks and/or leaf packs and/or emergent H Low-tide refugia (pools)
vegetation I Sand bottom
C Multiple snags and logs (including lap trees)J 5% vertical bank along the marsh
D 5% undercut banks and/or root mats and/or roots K Little or no habitat
in banks extend to the normal wetted perimeter
E Little or no habitat
11.Bedform and Substrate – assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
11a.Yes No Is assessment reach in a natural sand-bed stream? (skip for Coastal Plain streams)
11b.Bedform evaluated. Check the appropriate box(es).
A Riffle-run section (evaluate 11c)
B Pool-glide section (evaluate 11d)
C Natural bedform absent (skip to Metric 12, Aquatic Life)
11c.In riffles sections, check all that occur below the normal wetted perimeter of the assessment reach – whether or not submerged.
Check at least one box in each row (skip for Size 4 Coastal Plain Streams and Tidal Marsh Streams). Not Present (NP) =
absent, Rare (R) = present but ≤ 10%, Common (C) = > 10-40%, Abundant (A) = > 40-70%, Predominant (P) = > 70%. Cumulative
percentages should not exceed 100% for each assessment reach.
NP R C A P
Bedrock/saprolite
Boulder (256 – 4096 mm)
Cobble (64 – 256 mm)
Gravel (2 – 64 mm)
Sand (.062 – 2 mm)
Silt/clay (< 0.062 mm)
Detritus
Artificial (rip-rap, concrete, etc.)
11d.Yes No Are pools filled with sediment? (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
12.Aquatic Life – assessment reach metric (skip for Size 4 Coastal Plain streams and Tidal Marsh Streams)
12a.Yes No Was an in-stream aquatic life assessment performed as described in the User Manual?
If No, select one of the following reasons and skip to Metric 13. No Water Other:
12b.Yes No Are aquatic organisms present in the assessment reach (look in riffles, pools, then snags)? If Yes, check
all that apply. If No, skip to Metric 13.
1 >1 Numbers over columns refer to “individuals” for size 1 and 2 streams and “taxa” for size 3 and 4 streams.
Adult frogs
Aquatic reptiles
Aquatic macrophytes and aquatic mosses (include liverworts, lichens, and algal mats)
Beetles (including water pennies)
Caddisfly larvae (Trichoptera [T])
Asian clam (Corbicula )
Crustacean (isopod/amphipod/crayfish/shrimp)
Damselfly and dragonfly larvae
Dipterans (true flies)
Mayfly larvae (Ephemeroptera [E])
Megaloptera (alderfly, fishfly, dobsonfly larvae)
Midges/mosquito larvae
Mosquito fish (Gambusia ) or mud minnows (Umbra pygmaea)
Mussels/Clams (not Corbicula )
*********************************REMAINING QUESTIONS ARE NOT APPLICABLE FOR TIDAL MARSH STREAMS****************************Check for TidalMarsh Streamsonly
Other fish
Salamanders/tadpoles
Snails
Stonefly larvae (Plecoptera [P])
Tipulid larvae
Worms/leeches
13.Streamside Area Ground Surface Condition – streamside area metric (skip for Tidal Marsh Streams and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB). Consider storage capacity with regard to both overbank flow and
upland runoff.
LB RB
A A Little or no alteration to water storage capacity over a majority of the streamside area
B B Moderate alteration to water storage capacity over a majority of the streamside area
C C Severe alteration to water storage capacity over a majority of the streamside area (examples include: ditches, fill,
soil, compaction, livestock disturbance, buildings, man-made levees, drainage pipes)
14.Streamside Area Water Storage – streamside area metric (skip for Size 1 streams, Tidal Marsh Streams, and B valley types)
Consider for the Left Bank (LB) and the Right Bank (RB) of the streamside area.
LB RB
A A Majority of streamside area with depressions able to pond water ≥ 6 inches deep
B B Majority of streamside area with depressions able to pond water 3 to 6 inches deep
C C Majority of streamside area with depressions able to pond water < 3 inches deep
15.Wetland Presence – streamside area metric (skip for Tidal Marsh Streams)
Consider for the Left Bank (LB) and the Right Bank (RB). Do not consider wetlands outside of the streamside area or within the
normal wetted perimeter of assessment reach.
LB RB
Y Y Are wetlands present in the streamside area?
N N
16.Baseflow Contributors – assessment reach metric (skip for size 4 streams and Tidal Marsh Streams)
Check all contributors within the assessment reach or within view of and draining to the assessment reach.
A Streams and/or springs (jurisdictional discharges)
B Ponds (include wet detention basins; do not include sediment basins or dry detention basins)
C Obstruction that passes some flow during low-flow periods within assessment area (beaver dam, bottom-release dam)
D Evidence of bank seepage or sweating (iron oxidizing bacteria in water indicates seepage)
E Stream bed or bank soil reduced (dig through deposited sediment if present)
F None of the above
17.Baseflow Detractors – assessment area metric (skip for Tidal Marsh Streams)
Check all that apply.
A Evidence of substantial water withdrawals from the assessment reach (includes areas excavated for pump installation)
B Obstruction not passing flow during low flow periods affecting the assessment reach (ex: watertight dam, sediment deposit)
C Urban stream (≥ 24% impervious surface for watershed)
D Evidence that the stream-side area has been modified resulting in accelerated drainage into the assessment reach
E Assessment reach relocated to valley edge
F None of the above
18.Shading – assessment reach metric (skip for Tidal Marsh Streams)
Consider aspect. Consider “leaf-on” condition.
A Stream shading is appropriate for stream category (may include gaps associated with natural processes)
B Degraded (example: scattered trees)
C Stream shading is gone or largely absent
19.Buffer Width – streamside area metric (skip for Tidal Marsh Streams)
Consider “vegetated buffer” and “wooded buffer” separately for left bank (LB) and right bank (RB) starting at the top
of bank out to the first break.
Vegetated Wooded
LB RB LB RB
A A A A ≥ 100-feet wide or extends to the edge of the watershed
B B B B From 50 to < 100-feet wide
C C C C From 30 to < 50-feet wide
D D D D From 10 to < 30-feet wide
E E E E < 10-feet wide or no trees
20.Buffer Structure – streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Vegetated" Buffer Width).
LB RB
A A Mature forest
B B Non-mature woody vegetation or modified vegetation structure
C C Herbaceous vegetation with or without a strip of trees < 10 feet wide
D D Maintained shrubs
E E Little or no vegetation
21.Buffer Stressors – streamside area metric (skip for Tidal Marsh Streams)
Check all appropriate boxes for left bank (LB) and right bank (RB). Indicate if listed stressor abuts stream (Abuts), does not abut but
is within 30 feet of stream (< 30 feet), or is between 30 to 50 feet of stream (30-50 feet).
If none of the following stressors occurs on either bank, check here and skip to Metric 22:
Abuts < 30 feet 30-50 feet
LB RB LB RB LB RB
A A A A A A Row crops
B B B B B B Maintained turf
C C C C C C Pasture (no livestock)/commercial horticulture
D D D D D D Pasture (active livestock use)
22.Stem Density – streamside area metric (skip for Tidal Marsh Streams)
Consider for left bank (LB) and right bank (RB) for Metric 19 ("Wooded" Buffer Width).
LB RB
A A Medium to high stem density
B B Low stem density
C C No wooded riparian buffer or predominantly herbaceous species or bare ground
23.Continuity of Vegetated Buffer – streamside area metric (skip for Tidal Marsh Streams)
Consider whether vegetated buffer is continuous along stream (parallel). Breaks are areas lacking vegetation > 10-feet wide.
LB RB
A A The total length of buffer breaks is < 25 percent.
B B The total length of buffer breaks is between 25 and 50 percent.
C C The total length of buffer breaks is > 50 percent.
24.Vegetative Composition – First 100 feet of streamside area metric (skip for Tidal Marsh Streams)
Evaluate the dominant vegetation within 100 feet of each bank or to the edge of the watershed (whichever comes first) as it contributes
to assessment reach habitat.
LB RB
A A Vegetation is close to undisturbed in species present and their proportions. Lower strata composed of native
species, with non-native invasive species absent or sparse.
B B Vegetation indicates disturbance in terms of species diversity or proportions, but is still largely composed of native
species. This may include communities of weedy native species that develop after clear-cutting or clearing or
communities with non-native invasive species present, but not dominant, over a large portion of the expected strata or
communities missing understory but retaining canopy trees.
C C Vegetation is severely disturbed in terms of species diversity or proportions. Mature canopy is absent or communities
with non-native invasive species dominant over a large portion of expected strata or communities composed of planted
stands of non-characteristic species or communities inappropriately composed of a single species or no vegetation.
25.Conductivity – assessment reach metric (skip for all Coastal Plain streams)
25a.Yes No Was a conductivity measurement recorded?
If No, select one of the following reasons. No Water Other:
25b.Check the box corresponding to the conductivity measurement (units of microsiemens per centimeter).
A <46 B 46 to < 67 C 67 to < 79 D 79 to < 230 E ≥ 230
Notes/Sketch:
Assessment Reach of S2 runs from the upslope end of Wetland 3 (W3) to the downslope end of W3 where the stream enters a culvert.
Notes of Field Assessment Form (Y/N)
Presence of regulatory considerations (Y/N)
Additional stream information/supplementary measurements included (Y/N)
NC SAM feature type (perennial, intermittent, Tidal Marsh Stream)
(4) Floodplain Access
(4) Wooded Riparian Buffer
(4) Microtopography
(3) Stream Stability
(4) Channel Stability
(4) Sediment Transport
(4) Stream Geomorphology
(2) Stream/Intertidal Zone Interaction
(2) Longitudinal Tidal Flow
(2) Tidal Marsh Stream Stability
(3) Tidal Marsh Stream Geomorphology
(1) Water Quality
(2) Baseflow
(2) Streamside Area Vegetation
(3) Upland Pollutant Filtration
(3) Thermoregulation
(2) Indicators of Stressors
(2) Aquatic Life Tolerance
(2) Intertidal Zone Filtration
(1) Habitat
(2) In-stream Habitat
(3) Baseflow
(3) Substrate
(3) Stream Stability
(3) In-stream Habitat
(2) Stream-side Habitat
(3) Stream-side Habitat
(3) Thermoregulation
(2) Tidal Marsh In-stream Habitat
(3) Flow Restriction
(3) Tidal Marsh Stream Stability
(4) Tidal Marsh Stream Geomorphology
(3) Tidal Marsh In-stream Habitat
(2) Intertidal Zone Habitat
Overall
NC SAM Stream Rating Sheet
Accompanies User Manual Version 2.1
HIGH
HIGH
USACE/
All Streams
NCDWR
Intermittent
NA
NA
(2) Flood Flow
ClearWater Env. Consultant
March 30, 2020
NO
YES
Perennial
(2) Baseflow
Stream Category Assessor Name/Organization
LOW
Mb2
Stream Site Name ASU Child Care Date of Evaluation
MEDIUM
(4) Tidal Marsh Channel Stability
MEDIUM
HIGH
NA
NA
HIGH
NA
HIGH
(3) Tidal Marsh Channel Stability
(3) Streamside Area Attenuation
Function Class Rating Summary
(1) Hydrology
NA
HIGH
HIGH
HIGH
MEDIUM
NA
NO
LOW
NA
NA
NA
NA
MEDIUM
HIGH
MEDIUM
MEDIUM
HIGH
HIGH
HIGH
HIGH
LOW
NA
NA
MEDIUM
NA
HIGH
HIGH
LOW