20231101 Ver 1_WRC Comments_20231012

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
October 12, 2023
Ms. Brooke Davis
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Duke Energy Cliffside Station Unit 5 Inactive Ash Basin Dam Decommissioning
SAW-2015-01426
UTs to Broad River and Wetland, Rutherford and Cleveland Counties
Dear Ms. Davis
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
individual permit application to impact 0.9 acre of wetland for dam decommissioning and
stormwater channel creation in Rutherford and Cleveland counties. 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).
Wild trout reproduction should not be impacted by project activities, and a trout moratorium is
not needed. However, the Broad River supports two NC Significantly Rare species in the vicinity
of the project — Carolina Quillback (Carpoides sp. cf. cyprinus) and Carolina Foothills Crayfish
(Cambarus johni).
The application proposes to remove the main dam and possibly remove a saddle dam associated
with the Cliffside coal ash pond, which will be closed out. Coal combustion residual is currently
being removed from the pond. The project proposes to construct four rock -lined stormwater
channels within the pond footprint which would merge into a single rock -lined stormwater
channel downstream of the main dam. This channel would empty into the Broad River, and
gabion baskets would be used to stabilize the confluence. A 0.9-acre bottom hardwood forest
wetland would be permanently impacted for the construction of the downstream stormwater
channel. Two streams (S7 and S8) would be `restored' with these rock -lined channels.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Duke E Cliffside Ash Basin Dam Decommission Page 2 October 12, 2023
UTs Broad R and Wetland, Rutherford & Cleveland Co
We offer the following recommendations and notes on the application:
• This project provides an opportunity to restore Streams 7 and 8. Instead, these streams would
essentially be rock -lined stormwater channels, which would provide little aquatic and
riparian habitat. We strongly recommend that the design be re-evaluated and natural channel
design methods be used to restore these channels. A robust native riparian buffer should be
planted along these channels, as well.
• Gabion baskets are proposed to stabilize the outlet of the `stormwater channel' at the Broad
River. Gabion baskets are not long-term solutions for streambank stability, as they tend to fall
apart over time. We recommend that a bioengineering method of bank stabilization be used,
such as geolifts.
• Wetland impacts should be minimized as much as possible.
• The applicant should consult with the US Fish and Wildlife Service in order to assure that
impacts to bat habitat within the wetland are minimized.
• Mitigation is proposed at 1:1, with the NCWAM score for the impact wetland deemed Low.
We recommend that the mitigation ratio be 2:1, as this wetland provides valuable habitat
adjacent to the Broad River.
• A native forested riparian buffer of at least 100 ft in width should be maintained or replanted
along the Broad River.
• Any erosion control matting used should be free of nylon or plastic mesh, as this type of
mesh netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that
may last for years.
• Seeding specifications are not provided. Invasive species such as Tall Fescue, Kentucky
Bluegrass, and Sericea Lezpedeza should be avoided. Permanent seeding should be
comprised of native grasses and forbs.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
cc: James Cutler, WSP
Sue Homewood, Joey Winston, & Tyler Hickman, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Olivia Munzer, NCWRC