SpringsofNorthAshevillePhase2_UTsWagnerBr&Wetlands_Buncombe_NCWRCComments

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
March 7, 2024

Mr. Mitchell Anderson
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: Springs of North Asheville – Phase 2
UTs to Wagner Branch and Wetlands, Buncombe County

Dear Mr. Anderson:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 34 ft and temporarily impact 40 ft of unnamed tributaries
(UTs) to Wagner Branch and permanently impact 0.164 acre and temporarily impact 0.085 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.

The application proposes to complete the construction of a residential development that has been
the subject of two previous nationwide permits. Accounting for previous impacts, the cumulative
impacts to wetlands that require mitigation are 0.171 acre, and 0.205 acre of mitigation has been
purchased. The proposed project activities include sewer crossings that would permanently
impact 0.164 acre of wetland (with conversion of forested wetlands to herbaceous wetlands) and
two culverts. Temporary impacts would involve temporary clearing of additional wetland and
pump around areas for culvert installation. Impacted wetland areas will be seeded with native
wetland seed.

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.
Springs of North Asheville Phase 2 Page 2 March 7, 2024
UTs to Wagner Br & Wetlands, 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 temporary seeding specifications are not provided. Invasive species such as Tall Fescue,
and Sericea Lespedeza should not be planted within the wetland and riparian areas.
4. Streambank stabilization specifications include riprap. We strongly recommend planting
native shrubs and trees instead of 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.
5. Flag off wetland areas that are outside the impact area so that heavy equipment stays within
the impact area footprint.
6. Any heavy machinery used in the wetlands should be placed on timber mats to minimize soil
compaction.
7. 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.
8. Culvert material is not specified. We recommend against using high density polyethylene or
reinforced concrete material, as these smooth materials are less likely to hold stream
substrate and provide for movement of aquatic organisms like fish and salamanders.
9. Limit impervious surface to less than 10% or use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10%.
10. Use non-invasive native species and Low Impact Development (LID) technology in
landscaping. Using native species instead of ornamentals should reduce the need for water,
fertilizers and pesticides. Using LID technology in landscaping will not only help maintain
the predevelopment hydrologic regime, but also enhance the aesthetic and habitat value of
the site.
11. Protect and plant native riparian buffers on the site and set aside non-developed areas as
green space. Maintain open space areas with native 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,

Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program

ec: Tyson Kurtz, ClearWater Environmental
Joey Winston, NC Division of Water Resources