20230686 Ver 1_WRC Comments_20230523

0 NORTH CAROLINA WILDLIFE RESOURCES COMMISSION
Cameron Ingram, Executive Director
May 23, 2023
Ms. Amanda Jones
U.S. Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
Subject: WRC Comments on Greater Asheville Regional Airport Authority Apron Expansion Project,
Buncombe County, North Carolina
Ms. Jones,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the subject
information and are familiar with the habitat values of the area. Comments are provided in accordance
with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-
667e) and North Carolina General Statutes (G.S. 113 -13 1 et seq.).
Greater Asheville Regional Airport Authority (GRAA) is proposing to construct 652 parking spots within a
13.01-acre parcel. The GRAA would like authorization to impact 745 linear feet of stream (1,696 yd3 fill) and
0.062 acres of wetlands (298.1 yds3 of fill) by installing reinforced concrete pipe and clean fill dirt. The three
unnamed tributaries to the French Broad River are classified by the NC Division of Water Resources as
class `B" waters. GRAA proposes to mitigate impacts through payment to the NC Division of Mitigation
Services at a ratio of 1.5:1 for stream and cumulative wetland impacts.
Although there will be direct aquatic impacts associated with this planned construction, we do not oppose
this project. The current condition of the streams, both onsite and offsite, are generally poor and we
support the concept of offsite mitigation at other locations with more long-term potential for ecological
uplift. We do not have records of trout at this location and do not request the trout spawning moratorium.
We would request that the cleared riparian buffers be demarcated and restored to reduce sedimentation
into the three streams. Although the site has already been extensively cleared, we would request that any
additional tree clearing be avoided during the summer bat maternity season (April 1 to August 15) to
reduce impacts to northern long-eared bat (Myotis septentrionalis).
The use of biodegradable and wildlife -friendly sediment and erosion control devices is strongly
recommended. Silt fencing, fiber rolls and/or other products should have loose -weave netting that is made
of natural fiber materials with movable joints between the vertical and horizontal twines. Silt fencing that
has been reinforced with plastic or metal mesh should be avoided as it impedes the movement of
terrestrial wildlife species. Excessive silt and sediment loads can have detrimental effects on aquatic
resources including destruction of spawning habitat, suffocation of eggs, and clogging of gills.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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May 23, 2023
Scoping — AVL Parking Expansion (Asheville)
Thank you for the opportunity to review and comment on this regulatory action. If I can provide further
assistance, please call [phone] or email dou .bg esler(cr�,ncwildlife.org.
Sincerely,
Doug Besler (on behalf of Andrea Leslie, Habitat Conservation Coordinator)
Regional Fishery Supervisor
Inland Fisheries Division
Cc: Andrea Leslie, Habitat Conservation Coordinator, NCWRC
Paul Wojoski, Permitting & Buffer Unit, NC DWR