20160848 Ver 1_USFWS comments on Draft Prospectus and site visit_20160907

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa Street
Asheville, North Carolina 28801
September 7, 2016
Mr. Steve Kichefski
US Army Corps of Engineers
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, North Carolina 28801
Dear Mr. Kichefski:
Subject: Comments on Preliminary Draft Prospectus for the Proposed Asheville School Stream
Mitigation Bank, Buncombe County, North Carolina
Log Number 4-2-16-556
The U.S. Fish and Wildlife Service (Service) received a copy of the preliminary draft prospectus
for the Asheville School Bank dated July 20, 2016. On August 22, 2016, we attended a site visit.
We have reviewed the information in the draft prospectus and provide the following comments
in accordance with the provisions of the Fish and Wildlife Coordination Act, as amended
(16 U.S.C. 661-667e), and section 7 of the Endangered Species Act of 1973, as amended
(16 U.S.C. 1531-1543) (Act).
Project Description
The draft prospectus for the proposed project is still in development and was incomplete at the
time of our review and site visit. We anticipate that there will be some changes and clarifications
in any future versions of the prospectus. Based on the information provided, the proposed Bank
site is located on 132 acres in Asheville, North Carolina and would consist of approximately
9,715 linear feet of restoration, 1,030 linear feet of enhancement, 6.25 acres of wetland
restoration, and potentially an undefined acreage of wetland creation along a portion of Ragsdale
Creek and several of its first and second order tributaries. Additional project objectives include
the removal of a breached earthen dam and restoration of a portion of Ragsdale Creek that flows
through the former lake bed and daylighting sections of culverted tributaries.
The proposed bank would seek to provide compensatory stream and wetland mitigation credits
for unavoidable impacts resulting from development in the Hydrologic Unit Code (HUC)

06010105 (the Hominy Creek watershed). However, at this time, the draft prospectus does not
specify the proposed amount of credits the bank would generate or a credit release schedule.
Federally Protected Species
According to Service records, suitable summer roosting habitat may be present on site for the
federally threatened northern long-eared bat (Myotis septentrionalis). However, the final 4(d)
rule (effective as of February 16, 2016), exempts incidental take of northern long-eared bat
associated with activities that occur greater than 0.25 miles from a known hibernation site, and
greater than 150 feet from a known, occupied maternity roost during the pup season (June 1 —
July 31). Based on the information provided, the project (which will likely require tree clearing)
would occur at a location where any incidental take that may result from associated activities is
exempt under the 4(d) rule. Still, we recommend incorporating a tree clearing moratorium (from
May 15 — August 15) into project plans to further reduce the probability of take of this species.
The Service has record of no other federally protected species in the project area at this time.
The mountain blotched chub (Erimystax insignis eristigma) is a federal species of concern
known from Hominy Creek approximately 1 mile downstream from the proposed project. This
fish lives in medium-sized creeks and small rivers, depends on good water quality, fast -water
habitats that are dominated by coarse lithic substrates. The breached earthen dam at the east end
of the proposed Bank may be a significant barrier for this species, limiting its ability to access
upstream habitats. Although the mountain blotched chub is not currently afforded protections
under the Act, incorporating proactive measures into project plans may help preclude the need to
list this species in the future.
Comments, Requests, and Recommendations
Since the draft prospectus for the proposed project is incomplete at this time, we expect that our
comments and recommendations will change with any future iterations. With that said, we offer
the following comments based on the information provided:
1) In general, it appears that full restoration is not warranted in many of the first order
tributary streams. The amount of disturbance required to accomplish restoration goals
may outweigh the biological benefit. Instead, preservation and enhancement activities
may be more appropriate in these streams to ensure that they will remain functional.
2) At least one tributary of Ragsdale Creek (UT 1) was not accurately mapped according to
the draft prospectus. Based on field observations, UTI appears to be a braided tributary
that flows east through a 3 -acre wetland between UT3 and Ragsdale Creek. According to
the draft prospectus, UTI would be relocated to bypass the wetland, flowing directly into
Ragsdale Creek (shown in figure 4.1). We are concerned that the proposed relocation of
this tributary may impact the function of this wetland. We request that the location of
this and all other streams be verified.
3) The idea of project phasing was suggested. The Service would prefer that the proposed
project not be phased unless the first phase is deemed to be sufficient if unaccompanied
by subsequent phases.
4) The proposed bank should develop a plan to monitor and manage for non-native invasive
species. We encourage the Sponsor and Mitigation Banking Instrument to investigate the
2

extent of the hemlock wooly adelgid infestation in the project area, and if warranted,
develop an integrated pest management program that utilizes biological control of this
pest.
5) According to the information provided, a 151 -foot -wide riparian buffer easement is
proposed for most of the project site. However, a narrower 30 -foot -wide buffer is
proposed in some areas near a sanitary sewer line. Although constraints may prevent a
full 151 -foot buffer in some places, a buffer of greater than 30 -feet wide may be possible
along the sewer line. We encourage the Sponsor to explore the possibility of extending
the riparian buffer wherever possible.
If the Sponsor and MBI can address our concerns and fully consider our recommendations, the
Service may support any efforts to restore and protect the water quality in the proposed
mitigation bank area. We request the opportunity to review future design and implementation
plans as more information becomes available.
We appreciate the opportunity to review this draft prospectus. If we can be of assistance or if
you have any questions, please contact Mr. Byron Hamstead of our staff at 828/258-3939,
Ext. 225. In any future correspondence concerning this project, please reference our Log
Number 4-2-16-556.
Sincerely,
- - original signed - -
Janet A. Mizzi
Field Supervisor
3