20071841 Ver 7_WRC Comments_20210804

® North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
August 4, 2021
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Asheville Airport Area 1 Structural Fill
Wetland and UT to French Broad River, Buncombe County
SAW-2018-00173
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the
individual 404 permit application for the Asheville Airport Area 1 Structural Fill project, which
would impact 0.56 acre of wetland and 12 ft of an unnamed tributary (UT) to the French Broad
River in Buncombe 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).
This site drains to the French Broad River, which supports Blotched Chub (Erimystax insignis,
NC Significantly Rare), and father downstream, supports Appalachian Elktoe (Alasmidonta
raveneliana, US and NC Endangered). Wild trout reproduction should not be impacted by the
project, and a trout moratorium is not needed.
The Greater Asheville Regional Airport Authority proposes to place a permanent cap on existing
fill consisting of coal combustion residuals and convert two sediment basins to dry detention
stormwater basins to meet NC Department of Environmental Quality requirements. This will
involve culverting 12 ft of an UT to the French Broad River and filling 0.56 acre of wetland.
Both the stream and the wetland rate out medium with NCSAM and NCWAM, and a 1:1
mitigation ratio is proposed. We recommend that a ratio of at least 2:1 be used to mitigate for
these impacts. These features provide important ecological functions, especially as the
Endangered Appalachian Elktoe has recently been rediscovered in the French Broad River
downstream of the project area, and wetlands in the larger French Broad River valley are rare.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Asheville Airport Area 1 Structural Fill Page 2 August 4, 2021
UT French Broad R, Buncombe Co
Thank you for the opportunity to review and comment on this project. Please contact meat
[phone] if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: David Vance, Geosyntec Consultants
Andrew Moore & Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service