20170426 Ver 1_WRC Comments_20170531

North Carolina Wildlife Resources Commission 15
Gordon Myers, Executive Director
May 31, 2017
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Duke Energy Asheville Combined Cycle Project Laydown Area
UTs to the French Broad River, Buncombe County
Action ID#: SAW -2014-00189
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
individual permit application to fill 0.38 acre of wetland and permanently impact 972 ft of unnamed
tributaries (UTs) to the French Broad River in Buncombe County. NCWRC staff visited the impact
site on March 24, 2017. 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).
Duke Energy's Asheville Stream Electric Plant Station is sited on Lake Julian, which impounds
several UTs to the French Broad River. The impact site is located on another UT to the French
Broad River, which enters the river just upstream of the main outlet stream of Lake Julian. The
impact site contains streams, a small pond, and wetlands on the upstream fringe of the pond. The
streams at the impact site are generally high quality, small headwater forested streams that host
healthy populations of common salamanders, such as Blue Ridge Two -lined Salamander (Eurycea
wilderae), Seal Salamander (Desmognathus monticola), Carolina Mountain Dusky Salamander
(Desmognathus carolinensis), and Northern Dusky Salamander (Desmognathus fuscus).
The project should not impact trout and activities do not need to be avoided during the trout
spawning moratorium. The French Broad River in the project vicinity contains the rare Southern
Blotched Chub (Erimystax insignis eristigma, US Federal Species of Concern, NC Significantly
Rare).
The impacts are associated with Duke Energy's Western Carolinas Modernization Project, which
involves the construction of two combined cycle natural gas -fueled electric generating units and the
retirement of two coals units. According to the permit application, an additional laydown area is
needed for the receipt, storage, or assembly of equipment and materials. Six alternatives were
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Duke Energy Asheville CC Page 2 May 31, 2017
Buncombe County
considered for the laydown area, and the preferred alternative was chosen based on numerous factors;
although the chosen (preferred) alternative has the fewest constraints associated with transportation,
accessibility, and security, it is the only alternative that involves direct impacts to surface waters and
wetlands. The chosen alternative site is 12.2 acres, with 5.9 acres deemed as usable project space in
a primarily wooded area with streams, a pond, and wetlands on the upstream end of the pond.
Development of the site will involve clearing and grading for the laydown area and construction of a
sediment basin. The pond will be eliminated, the wetlands filled, and the streams culverted.
The permit application does not provide plan details the laydown area, such as staging, sediment and
erosion control, culvert type and installation, or stormwater management.
NCWRC recommends that stormwater be managed to mimic pre -development hydrologic conditions,
as increased impervious cover will result in increased stormwater flows capable of destabilizing
stream channels and impacting in -stream habitat and biota.
Mitigation
Mitigation is proposed at a 2:1 mitigation ratio for impacts to 926.5 ft on two streams with NC
Stream Assessment Method (NCSAM) scores of high. Mitigation is proposed at a 1:1 mitigation
ratio for impacts to 46 ft on a stream with a NCSAM score of medium. Impacts to 0.38 acres of
wetland will be mitigated at a 2:1 ratio. Due to the quality of the streams to be impacted, we
recommend that a 2:1 mitigation ratio be used for all stream impacts, whether rated High or Medium
through NCSAM.
Stream mitigation credits are proposed to be obtained through either the Anderson Farm or Wash
Creek mitigation bank. Wetland mitigation credits would be obtained through NC Division of
Mitigation Services In -Lieu Fee Program. We do not object to this mitigation proposal. However,
NCWRC is aware of important stream and wetland restoration opportunities at other sites in the
upper French Broad Basin. We support obtaining mitigation at one of these sites instead of or in
combination with that proposed. Duke Energy could explore these opportunities with the help of a
local land trust, Carolina Mountain Land Conservancy. NCWRC would welcome the opportunity to
work with Duke Energy and sister agencies to obtain high quality mitigation for this site and any
future projects.
Thank you for the opportunity to review and comment on this project. Please contact me at (828)
558-6011 if you have any questions about these comments or need further assistance.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Steve Cahoon, Duke Energy Progress, LLC
Dicky Harmon, Amec Foster Wheeler
Zan Price and Jennifer Burdette, NC Division of Water Resources
Bryan Tompkins, US Fish and Wildlife Service
Lori Williams and David Cox, NCWRC