20201125 Ver 1_WRC Comments_20201104

® North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
November 4, 2020
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Horsepasture River Wastewater Treatment Plant and Collection System
Improvements
Horsepasture River, UT, and wetland, Jackson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to construct approximately 16,000 ft of sewer line and a new wastewater treatment plant,
temporarily impacting 102 ft and permanently impacting 60 ft of the Horsespasture River and an
unnamed tributary (UT), and temporarily impacting 0.01 acre and permanently impacting 0.08 acre
of wetland in Jackson County. 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).
Wild Brown Trout and Rainbow Trout are found in the project vicinity, and in -stream activities
should be avoided between October 15 and April 15 to minimize impacts to trout reproduction. In
addition, the Horsepasture River supports the Yellowfin Shiner [Notropis lutipinnis, NC Special
Concern (SC)], Chauga Crayfish (Cambams chaugensis, NC SC), and French Broad River Crayfish
(Cambarus reburms, US Federal Species of Concern, NC Significantly Rare). Effective erosion and
sediment control on this proj ect is essential to protect these species and their habitats.
The proj ect proposes to build a new 0.125 mgd wastewater treatment plant (WWTP) to respond to
current and requested wastewater treatment capacity in the upland area of the proj ect parcel. It
would also involve the construction of approximately 16,000 ft of sewer line in the US 64 maintained
right-of-way. The WWTP would use an advanced tertiary treatment process involving a disk filter
and UV disinfection, as well as a flow equalization basin to reduce peak flows. As mentioned in our
2016 scoping comments, we recommend that the treatment process be designed with technology that
is known to reduce or eliminate PPCPs and EDCs from wastewater. Some measures that appear to
provide effective reduction or elimination of these emerging contaminants include membrane
bioreactors, granular activated carbon, powdered activated carbon, ozonation, and combinations of
these treatment technologies.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Horsepasture WWTP Page 2 November 4, 2020
Horsepasture & UT, Jackson Co
In order to construct the access road to the WWTP, a temporary causeway with multiple culverts,
riprap, and concrete would be constructed to cross the Horsepasture River. A bridge would be
constructed and the causeway removed. All impacted stream banks would be planted with a native
seed mix and live staked with native plants.
We offer the following recommendations to minimize impacts to fish and wildlife:
I. In -channel work should be accomplished as quickly as possible and vigilance used in sediment
and erosion control during site preparation, construction, and clean up. Disturbed areas should be
seeded, mulched and/or matted as soon as possible, preferably at the end of each workday.
2. Disturbed wetland areas should be reseeded with a native wetland seed mix.
3. Any erosion control matting used should be free of plastic or nylon mesh, as this type of mesh
frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last for years.
4. Wetlands should be clearly marked and areas outside of the work area flagged or fenced in order
to exclude machinery from them.
5. Any equipment that is used in wetlands resulting in temporary impacts should be set on timber
mats.
6. In -stream activities should be avoided between October 15 and April 15 to minimize impacts to
wild trout reproduction.
7. The proposed permanent culvert crossing on the UT to Horsepasture River would be a double
HDPE culvert. We recommend against using HDPE material, as this slick material is less likely
to hold stream substrate and provide for movement of aquatic organisms like fish and
salamanders. In addition, we recommend against using multiple culverts set at the same
elevation, as they can often in one culvert carrying most or all of the flows over time; this can
cause channel instability and problems with aquatic organism passage.
8. Tall Fescue is specified in the planting plan for upland areas and ditches/open areas. Tall Fescue
is highly invasive and an alternative species should be used.
Thank you for the opportunity to review and comment on this project. Please contact me at (828)
400-4223 if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Jon Swaim, McGill & Associates
Kaylie Yankura, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Powell Wheeler and Lori Williams, NCWRC