20071841 Ver 8_WRC Comments_20240521

® North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
May 21, 2024
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Asheville Airport Runway Object Free Area Extension Project
UT to French Broad River, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the
individual 404 permit application for the Asheville Airport Runway Object Free Area Extension
Project, which would impact 242 ft of an unnamed tributary (UT) to the French Broad River (or
Cane Creek) 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).
This site drains to the French Broad River, which supports Blotched Chub (Erimystax insignis,
NC Threatened) and Eastern Hellbender (Cryptobranchus alleganiensis, US Federal Species of
Concern, NC Special Concern). Wild trout reproduction should not be impacted by the project,
and a trout moratorium is not needed.
The Greater Asheville Regional Airport Authority proposes to extend an existing culvert to
address security concerns, flooding, and stream instability within their Object Free Area. An
existing culvert, permitted in 2016, will be replaced and extended to total 365 ft. The culvert
would be reinforced concrete pipe (RCP).
Mitigation is proposed at 1:1 due to the low NCSAM rating. However, we argue that the low
NCSAM rating is in part due to the presence of the airport and their past manipulation of the
stream; we recommend that a ratio of at least 1.5:1 be used to mitigate for these impacts.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Asheville Airport ROFA Extension Page 2 May 21, 2024
UT French Broad R, Buncombe Co
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 seeded, mulched and/or matted as soon as possible, preferably at the end of
each work day.
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. We recommend against using RCP or high density polyethylene (HDPE) culvert materials, as
these smooth materials are less likely to hold stream substrate and provide for movement of
aquatic organisms like fish and salamanders.
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,
dA4­1,�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
cc: Eric Romaniszyn, Clearwater Environmental
Joey Winston & Sue Homewood, NC Division of Water Resources