20231456 Ver 1_WRC Comments_20240124

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
January 24, 2024
Mr. Mitchell Anderson
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Weaverville Pump Station and Force Main Improvements
Reems Creek, Blue Branch, and UTs, Buncombe County
Dear Mr. Anderson:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 216 ft of Reems Creek and an unnamed tributary (UT) and
0.583 acre of wetland, as well as temporarily impact 882 ft of Reems Creek, Blue Branch, and
UTs and 0.089 acre of wetland in Buncombe County. 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 Blotched Chub (Erimystax insignis, NC Threatened) is found in the
vicinity of the project area on Reems Creek.
The application proposes to replace two pump stations and upgrade 16,250 ft of sewer line and
associated infrastructure. Streams will be crossed via trench cut crossings and banks stabilized
either with riprap or with riprap and livestakes. Heavy equipment will cross wetlands on mud
mats, impacted wetlands will be seeded with native wetland seed, and wetland soils will be
stockpiled and replaced in the trenches cut through the wetlands. Permanent wetland impacts
result from converting forested wetlands to herbaceous wetlands for rights -of -way, and 1:1
mitigation will be provided.
We offer the following recommendations to minimize impacts to the aquatic community:
1. In -channel work should be accomplished as quickly as possible and vigilance used in
sediment and erosion control during site preparation, construction, and clean up. Disturbed
areas should be stabilized at the end of each work day.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Weaverville Pump Station and Force Main Page 2 January 24, 2024
Reems Cr, Blue Br, UTs, Buncombe Co
2. 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.
3. The seeding specifications include Weeping Lovegrass, Bermudagrass, Tall Fescue, and
Sericea Lespedeza, which are invasive species and should not be planted within the wetland
and riparian areas. We recommend using an annual grain such as Oats or Rye, Red Clover,
and Creeping Red Fescue. A permanent native riparian seed mix should be used within the
riparian corridor.
4. Stream channels at sewer crossings should be restored to near pre -disturbance conditions.
Channel dimensions should mimic the existing dimensions, and the stream bed should set be
at the pre-existing elevation. At least 6-8 inches of natural bed material should be placed on
top of the restored stream channel bed; this bed material should mimic that which is found in
the stream bed.
5. We strongly recommend planting native shrubs and trees instead of (or at least in addition to)
using riprap. Even a narrow line of woody vegetation can afford wildlife benefits, bank
stabilization, and stream shading. Banks should be stabilized with a seed mix that includes a
quick -growing temporary seed and native riparian vegetation.
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,
zav''#�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
cc: Mona Ellum, Ellum Engineering
Andrew Moore, NC Division of Water Resources