20221671 Ver 1_USACE Comments 2-6-23_20230206

Moore, Andrew W
From: Fuemmeler, Amanda J CIV USARMY CESAW (USA) <[e-mail]>
Sent: Monday, February 6, 2023 12:45 PM
To: Owen Carson
Cc: Moore, Andrew W
Subject: [External] Woodfin Wave Corps Comments/Request for Additional Information
Attachments: DWR_addinfo.pdf; USFWS_PNcomments.pdf; WRCComments.pdf; EPA_comments.pdf
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Owen,
Attached are the comments received in response to the Public Notice issued for the application proposing the
installation of a whitewater wave on the French Broad River at the Riverside Park location.. After a review of these
comments and the submitted application, below are the comments/questions the Corps has. Please provide your
response within 30 days.
1. Aquatic life passage concerns— please provide any completed studies that document if/how aquatic life passage
will be affected by this project.
2. Sediment transport concerns — please provide any completed studies that document if/how sediment transport
will be affect by this project.
3. Section 7 ESA Consultation — Based upon information submitted to date and knowledge of presence of federally
endangered/threatened species and their habitat, several species may be affected by this project. The Corps has
determined that this project 'may affect but not likely to adversely affect" (MANLAA) the following species: Gray
bat (Myotis grisescens) and Northern Long Eared Bat (Myotis septentrionalis). The Corps will serve as the lead
federal agency to coordinate informally with USFWS on these species and additional conditions (e.g. tree
clearing moratoriums, lighting, etc.) will likely be needed/drafted to ensure no adverse effect to these species.
We have also determined that the project may affect the Appalachian Elktoe (Alasmidonta raveneliana),
however the extent of this affect has not been determined at this time. Please provide any documents to
include the results of mussel surveys in the project area so that we can coordinate with USFWS on a final affect
determination and the next coordination steps. If determined that the project will adversely affect the
Appalachian Elktoe, a Biological Assessment (BA) will be required to be drafted and submitted to USFWS for
review as referenced in their January 6, 2023 comment letter (enclosed).
4. Alternatives Analysis: Please provide a detailed discussion of alternative site locations to include river reaches
in/around Asheville as well as specific sites that were evaluated within the Asheville reach chosen. The
discussion should also provided selection criteria that was used to determine which sites were considered the
most practicable based on the applicant's purpose/need. Please provide an electronic copy of a previous 2016
study entitled "Site Visit and Conceptual Design Study" which covers some alternatives and should be expanded
to address the above comment. Specifically, please include a discussion to the site known as the "The Ledges"
and whether it was considered a viable alternative site/location for the Wave.
5. Craggy Dam Removal — please address the viability of the project in the event that the Craggy Dam is removed.
6. Access from Norfolk -Southern Railway Side — please provide a discussion/update if permission has been
received to construct a portion of the Wave from property owned by Norfolk Southern immediately adjacent to
an existing rail line.
7. FEMA Approval — please provide an update on if FEMA approval has been received or when approval is
expected.
8. Safety Plan — please address how safety will be managed during and post -construction.
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9. DWR Request for Additional Information dated January 5, 2023 (enclosed)— please copy the Corps on your
response. The Corps shares the same concerns/has similar questions.
Feel free to reach out with any questions and the application will remain on hold until we work some of these
issues/comments.
Regulatory Specialist
USACE-Asheville Regulatory Field Office
828-271-7980 ext. 4225
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