20230518 Ver 1_HE-0001_DWR 20230518v1_SAW 2021-01535_Buncombe_IP Application__NCWRC Comments_20230509

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North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
May 9, 2023
Lori Beckwith
U.S. Army Corps of Engineers,Asheville Regulatory Field Office
151 Patton Avenue,Room 208
Asheville,NC 28801
Kevin Mitchell
NCDEQ,DWR
2090 U.S. Hwy. 70
Swannanoa,N.C. 28778
SUBJECT: Comments on IP application for new interchange on 1-26 (future exit 35)and roadway
extension,Buncombe County(HE-0001,WBS 49472.1.2)
DWR 20230518 ver.l
SAW 2021-01535
Dear Ms. Beckwith and Mr. Mitchell,
The North Carolina Department of Transportation(NCDOT) applied for an Individual 404 Permit and
401 Certification for the subject project. Comments on the application from the North Carolina Wildlife
Resources Commission(NCWRC)are offered to help conserve the wildlife resources affected by the
project and to promote wildlife-based recreation in accordance with applicable provisions of the state and
federal Environmental Policy Acts (G.S. 113A-lthrough 113-10; 1 NCAC 25 and 42 U.S.C. 4332(2)(c),
respectively),the Clean Water Act of 1977(33 U.S.C.466 et seq.), and the Fish and Wildlife
Coordination Act(48 Stat. 401,as amended; 16 U.S.C. 661-667d).
The project will impact wetlands and unnamed tributaries to the French Broad River for a new
interchange on I-26(future exit 35)and roadway extension. This project developed under the merger
process.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh,NC 27699-1721
Telephone: [phone] • Fax: [phone]

HE-0001 Page 2 May 9,2023
Buncombe County
The French Broad River in the project area is cool water habitat that does not support trout. Therefore,if
a Nationwide or General permit applied,the trout moratorium would be waived for impacts to the river
and most tributaries in the region.
While trout are not a concern here,the river does support Appalachian Elktoe mussel(Alasmidonta
raveneliana, US endangered). Also, gray bats(Myotis grisescens,US endangered)are known to forage
along the river nearby. Conservation measures to protect those species have been included in the project
in coordination with the US Fish and Wildlife Service.
The NCWRC appreciates the considerations for stormwater management because the project is a new
roadway that will affect a relatively stable and good quality stream(SA). Preformed scour holes and
energy dissipators have been retained for stormwater outlets in several locations. According to the
stormwater analyses,run-off is not expected to increase appreciably(post-construction)except in stream
SG. As noted in the supplemental application information, outlet protection on the streambeds has been
removed from several locations.
While erosive velocities may not be predicted,the NCWRC recommends that NCDOT visually assess
culvert outlets and channels below the outlets after a large storm event(s), as possible,before the project
is closed-out. A particular area worth evaluating is site 3 where the outlet of the 66"RCP in SDX will
discharge into a channel realignment that does not include grade control. Erosion could occur in this
channel if the underlying soils are unconsolidated. Rock additions to the streambeds at culvert outlets and
stream relocation are recommended for some energy dissipation or grade control if channel instability
develops.
Thank you for the opportunity to review and provide recommendations on this project. Please contact me
at david.mchenakncwildlife.org or(828)476-1966 if you have any questions about these comments.
Cordially,
Z�IA_ ,
Dave McHenry,NCWRC Western DOT Coordinator
cc: McCray Coates,PE,NCDOT Division 13
Michael Turchy,NCDOT ECAP
Lauren Wilson,US Fish and Wildlife Service