20071841 Ver 6_Other Agency Comments_20160303

Burdette, Jennifer a
From:
Price, Zan (George)
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Thursday, March 03, 2016 5:45 PM
To:
Burdette, Jennifer a
Subject:
Fwd: Asheville Airport Runway/Taxiway/Cargo Expansion Permit Modification -
NCWRC comments
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Begin forwarded message:
From: "Leslie, Andrea J" <andrea.leslie@ncwildIife_org>
................................................................... _ ........._..._.
Date: March 3, 2016 at 12:05:33 PM EST
To: "Brown, David W SAW" <David.W.Brown@usa_c_e.:_a_rmy.mil>
.............................................................................
Cc: Rebekah Reid <rebel<ah@_rwenv_com>, "Price, Zan (George)" <Zan_Price @nc_denr_gov>, "byron
hampstead (byron Hamstead@fws_gov)" <byron Hamstead@fws_gov>
........ ..........
Subject: Asheville Airport Runway/Taxiway/Cargo Expansion Permit Modification - NCWRC comments
Attached are NCWRC's comments on the Asheville Airport Runway/Taxiway/Cargo Expansion
Permit Modification.
Andrea Leslie
Mountain Habitat Conservation Coordinator
NC Wildlife Resources Commission
20830 Great Smoky Mountain Expressway
Waynesville, NC 28786
828-558-6011; 828-400-4223 (cell)
www.ncwildlife.org
1

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
March 3, 2016
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Asheville Airport Runway, Taxiway, and Cargo Hold Expansion
Permit Modification Request (USAGE 2010-00036, NCDWQ Project 07-1841)
UT to French Broad River, Buncombe County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed a
request to modify a previously permitted project on the Asheville Airport property in Buncombe
County. The modification would culvert an additional 90 ft of an unnamed tributary (UT) to the
French Broad River, stabilize 1,430 ft of the same stream, and 6110.03 acre of wetland. 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. 661-6674).
Please refer to our comments on the original project, attached to this document. We do not
object to the expansion of the project, provided that the new 90 ft of stream impacts are mitigated
as proposed.
However, the proposed culvert is a double barreled culvert. Double culverts set at the same
elevation often result in one culvert carrying most or all of the flows over time; this can cause
channel instability and problems with aquatic organism passage. We recommend replacing the
double culvert with a spanning structure such as a bottomless arch instead. If a culvert must be
used, we recommend using a single larger squash pipe capable of carrying base and stormflows,
or, less preferred, a double barreled system with one culvert embedded appropriately and the
other culvert set at an elevation to capture flood events only.
We offer the following recommendations to minimize impacts to the aquatic community:
1. Vigilance must be used in sediment and erosion control during site preparation, construction,
and clean up.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Asheville Airport Expansion Permit Modification Page 2
UT French Broad River, Buncombe County
March 3, 2016
2. Any erosion control matting used be free of plastic or nylon 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 plan includes Tall Fescue for stabilization. Tall Fescue should be avoided, as it is
invasive and has minimal wildlife benefits.
4. An alternative (e.g., bottomless culvert, squash pipe, or least preferred, two culverts with one
set at flood elevation) to a double barreled culvert with both barrels set at the same elevation
should be used.
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: Rebekah Reid, ClearWater Environmental Consultants
Zan Price, NC Division of Water Resources
Byron Hampstead, US Fish and Wildlife Service

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
June 18, 2010
Ms. Tasha McCormick
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
Mr. Ian McMillan
NCDENR, Division of Water Quality, 401 Unit
1628 Mail Service Center
Raleigh, North Carolina 27699-1628
SUBJECT: Asheville Regional Airport Authority, Mr. Lew Bleiweis Individual Permit Application
Asheville Regional Airport Cargo Hold Expansion, Buncombe County
Action ID 2010-0036, DWQ No. 07-1841 V3
Dear Ms. McCormick and Mr. McMillan:
Mr. Lew Bleiweis of the Asheville Regional Airport Authority requested an Individual Permit from the U.S.
Army Corps of Engineers (ACOS) to fill 1,260 feet of tributaries to the French Broad River for another
expansion of the Asheville Regional Airport. North Carolina Wildlife Resources Commission (Commission)
staff attended the March 9, 2010 site meeting. Comments from the Commission are provided under
provisions of the Clean Water Act of 1977 (33 U.S.C. 466 et. seq.) and the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d).
The French Broad River near the airport supports a cool water fishery comprised of, in part, smallmouth bass
and muskellunge. Wetlands in this region are important to a variety of birds and other wildlife. Bog turtles
(NC Threatened) and mole and four -toed salamanders (NC Special Concern) have been found in wetlands
along the French Broad River within a few miles of the airport. Wetlands and the riparian areas on the
property are important for protecting water quality in the French Broad River; but streams here are generally
in poor condition due to stormwater run-off from the airport.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Asheville Airport Page 2 June 18, 2010
Buncombe
Extensive impervious cover from the proposed development has the potential to degrade downstream water
quality. Therefore, the Commission requests that effective storm water detention and treatment be
incorporated with the expansion and any existing developed areas that can be improved as well.
We recommend that this and other planned airport expansion projects be permitting collectively instead of in
phases as currently being done. This facilitates project evaluation, but, more importantly, ensures that
impacts to wetlands and streams for the airport as a whole are avoided and minimized to the extent practical.
Losses can be excessive when individual projects are not comprehensively planned. This is particularly trie
when development space is limited and all development must be in close proximity, such as with airport
expansions.
Mitigation for unavoidable impacts should reflect the quality of the impacted streams, but it also should
account for effects that the project is currently having on quality. The streams that will be impacted are in
poor condition due to historic impacts, like channel straightening of stream 1, but they also have been, and
continue to be, degraded by stormwater from the airport itself. For example, the stream at the south end of the
airport is highly unstable and eroding due to runoff from the runway and terminal areas. Therefore, we
recommend that the project's mitigation be supplemented with stormwater management practices and
restoration of stable channel morphology in that area. This effort combined with the proposed credit purchase
would provide compensatory that is commensurate with the ongoing and foreseeable impacts of this phase of
the greater airport expansion plans.
Thank you for the opportunity to review and comment on this project. Please contact me at (828) 452-
2546 extension 24 if there are any questions about these comments.
Sincerely,
Dave McHenry
Mountain Region Coordinator
Habitat Conservation Program
cc: Mr. Kevin Barnett, NC Division of Water Quality
Mr. Bryan Tompkins, US Fish and Wildlife Service
Ms. Becky Fox, USEPA