20230477 Ver 1_WRC Comments_20230725

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
July 25, 2023
Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Carrier Bridge Pump Station Replacement Project
French Broad River, UT, and Wetland, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to temporarily impact 393 ft of the French Broad River and unnamed tributary (UT) and
0.08 acre of wetland in Buncombe County. NCWRC staff visited the site on April 27, 2023. 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).
Project activities should not impact wild trout and do not need to be avoided during a trout
moratorium. However, there are records for the Appalachian Elktoe [Alasmidonta raveneliana, US
& NC Endangered (E)] and Blotched Chub (Erimystax insignis, NC Significantly Rare) in the French
Broad River upstream of the project location. Recent mussel surveys were performed within the
project location, and no listed mussels were found. Gray Bat (Myotis grisescens, US & NC
Endangered) is found in the vicinity of the project. For the Gray Bat, a forested riparian area is an
important habitat, as gray bats fly along river banks within the shelter of the trees.
The project involves the construction of two sewer line crossings across the French Broad River,
namely a 60-in gravity sewer line crossing and a dual 36-in force main crossing. Sewer lines would
be constructed in the French Broad River floodplain as well. Both sewer line crossings would be
performed via trench cut, with work done behind sheet pile or riprap coffer dams, which would
isolate the work areas from live flows. The coffer dams will be constructed to isolate one half of the
width of the river at a time; after a coffer dam is installed, water will be pumped out of the coffer
dammed area, the sewer line trench excavated and pipe installed, and the trench backfilled. In -stream
work is anticipated to take place for 9 months, from January 1 to October 1, 2026.
At the locations of the new sewer lines, 100 ft of riparian vegetation would be cleared and banks
would be stabilized once the work is completed. It appears that bioengineering methods will be used
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Carrier Bridge Pump Station Page 2 July 25, 2023
French Broad R, Buncombe Co
for stabilization, such as wood toe with geolift, vegetated geogrid, or Filtrexx Edgesaver Stream
Bank Stabilization. In other areas, riparian vegetation would be cleared as well for line installation;
riparian vegetation clearing should be minimized as much as possible.
While the in -river work is occurring, bank stability will be monitored. If banks reach a certain
threshold of instability, a larger bank stabilization contingency plan using bioengineering methods
will be implemented. This contingency plan will be developed and sent to agencies for review before
in -stream construction begins.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Work should be accomplished as quickly as possible and vigilance used in sediment and erosion
control during site preparation, construction, and clean up. Due to the possibility of listed species
in the French Broad River, we ask that disturbed areas be stabilized on a tight timeframe to
minimize risk of sediment loss, namely, the disturbed areas should be seeded, mulched and/or
matted as soon as possible, preferably at the end of each work day.
2. Seeding specifications have not been provided. Seeding mixes should not include invasive
species, such as Tall Fescue and Sericea Lespedeza. Permanent seed mixes should be comprised
of native grasses and forbs. An emphasis on pollinator -beneficial species should be made.
3. Removal of existing riparian vegetation should be minimized, and native shrubs and trees be
replanted wherever possible. We ask the applicant to provide a list of woodyspecies that will be
planted to NCWRC for review.
4. Any erosion control matting or bioengineering solutions used should be free of plastic or nylon
mesh, as this type of mesh netting frequently entangles wildlife and is slow to degrade, resulting
in a hazard that may last for years.
5. Effective dewatering structures need to be constructed and maintained. Water from dewatered
areas should be treated before discharged to remove suspended sediments.
6. Contingency plans for high flow events should be developed. These should include cleaning up
debris from coffer dams in the channel.
7. The weather forecast should be monitored closely; it is essential that concrete pours be done
during low flows and followed by several days of low flows to ensure dry conditions.
8. The applicant should have a robust communications plan to inform the public of safety concerns,
especially those associated with work in the river. We ask that the applicant inform NCWRC
when in -stream activities will begin so that we can educate anglers about safety concerns.
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,
dA4' � J
Annddr`e``a' Leslie
Mountain Region Coordinator, Habitat Conservation Program
cc: Eric Mularski, HDR
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Katherine Etchison & Luke Etchison, NCWRC