BrevardPumpStations_UTFrenchBroadR&Wetland_Transylvania_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]
April 2, 2024

Ms. Shannon Healy
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: Brevard Pump Stations
UT French Broad River and Wetland, Transylvania County

Dear Ms. Healy:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to temporarily impact 44 ft of an unnamed tributary (UT) to the French Broad River
and 0.067 acre of wetland in Transylvania 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 site is just upstream of a reach of the French Broad River that supports
the Appalachian Elktoe (Alasmidonta raveneliana, US and NC Endangered); this species is
especially sensitive to excess sediment, and excellent erosion and sediment control are important
to minimize impacts to this species.

The application proposes to construct 585 ft of new sewer line and install pump stations. The line
would cross an herbaceous wetland and a stream through open cut methods. The wetland soils
would be harvested and replaced into the trench and the area seeded with native wetland seed.
The stream would be regraded to pre-impact dimensions and stabilized with natural channel
design methods.

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.
Brevard Pump Stations Page 2 April 2, 2024
UT French Broad R & Wetland, Transylvania 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. Wetland work should be done from wetland mats. Flag off wetland areas that are outside the
impact area so that heavy equipment stays within the impact area footprint.
4. Open cut work through the stream must be done in the dry, and the stream planted with
native seed and woody 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: Eric Romaniszyn, ClearWater Associates
Joey Winston, NC Division of Water Resources