20170426 Ver 1_PN Comments_20170613

Homewood, Sue
From:Brown, David W CIV USARMY CESAW (US) <[e-mail]>
Sent:Tuesday, June 13, 2017 8:37 AM
To:Cahoon, Steve
Cc:Harmon, Richard G; Tompkins, Bryan; Leslie, Andrea J; Homewood, Sue; Price, Zan (George)
Subject:Comments Received to Public Notice - Asheville CC Natural Gas Plant Project
Attachments:2014-00189 Asheville CC Natural Gas Plant PN Comments.pdf
Action ID SAW-2014-00189

Steve Cahoon,

Attached are the comments the Corps received during the comment period of the public notice for your submitted permit
application associated with the Asheville CC Natural Gas Plant Project in Arden, Buncombe County, North Carolina. You are
requested to review the comments and submit to the Corps a document which responds/addresses the
comments/concerns/issues noted. Please submit this document by July 28, 2017, and copy USFWS, NCWRC, and NCDEQ-DWR on
this document. Once the Corps receives your response, a meeting with USFWS, NCWRC, NCDEQ-DWR, and the Corps may be
appropriate in order to review and discuss your submitted response.

If you have any questions please contact me.

Thank you,
David Brown, PG
Regulatory Specialist/Geologist
828-271-7980, ext. 4232
[e-mail]

USACE Wilmington District - Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006

The Wilmington District is committed to providing the highest level of support to the public. To help us ensure we continue to do
so, please complete the Customer Satisfaction Survey located at http://corpsmapu.usace.army.mil/cm_apex/f?p=136:4:0

1

(Sent via Electronic Mail)
Colonel Kevin P. Landers, Sr., Commander
USACE Wilmington District
69 Darlington Avenue
Wilmington, North Carolina 28403-1398
Dear Colonel Landers:
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
26313th Avenue South
St, Petersburg, Florida 33701-5505
http:llsero.nmfs.noaa.gov
71
May 10, 2017 r
,AY 2 017
.••RR•.. .............
NOAA's National Marine Fisheries Service (NMFS) reviewed the projects described in the
public notices listed below. Based on the information in the public notices, the proposed projects
would NOT occur in the vicinity of essential fish habitat (EFH) designated by the South Atlantic
Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS.
Present staffing levels preclude further analysis of the proposed work and no further action is
planned. This position is neither supportive of nor in opposition to authorization of the proposed
work.
Notice No. Applicant(s) Notice Date Comment Due Date
SAW -2010-01018 NCDOT 1-40 overpass May 5, 2017 June 5, 2017
at Liberty Road, STIP I-
4759
SAW -2014-00189 Duke Energy Progress May 5, 2017 June 5, 2017
LLC, Asheville CC
Project
Please note these comments do not satisfy consultation responsibilities under section 7 of the
Endangered Species Act of 1973, as amended. If an activity "may effect" listed species or critical
habitat under the purview of the NMFS, please initiate consultation with the Protected Resources
Division at the letterhead address.
Sincerely,
Pace Wilber for
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division

ENT OF yF
' F'ISII & WILDLIFE
SERVICE
a� �m United States Department of the Interior
_ FISH AND WILDLIFE SERVICE oa
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Asheville Field Office "wl OF T118
160 Zillicoa Street Suite #B
Asheville, North Carolina 28801
June 6, 2017
Mr. David Brown
Asheville Regulatory Field Office
U.S. Army Corps of Engineers
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
Dear Mr. Brown:
This is the report of the U.S. Fish and Wildlife Service (USFWS) and the Department of the Interior
on the U.S. Army Corps of Engineers' (Corps) Public Notice (PN) of an Individual Permit
Application (IPA) submitted by Mr. Wayne Smith of Duke Energy Carolinas, LLC (Duke Energy) to
impact about 972.5 linear feet of stream impacts, 0.87 -acres of permanent open water impacts, and
0.38 -acres of permanent wetland impacts associated with the Construction Laydown Areas at the
proposed Asheville Combined Cycle Plant Project, in Buncombe County, North Carolina.
Information for this report is based on information obtained by our staff at a scoping meeting held on
February 23, 2017, and a review of the PN issued by the Corps. The report is submitted in
accordance with the provisions of the National Environmental Policy Act; 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).
According to the information presented, the proposed project consists of clearing and preparing a
construction laydown area (Construction Laydown Area 3) associated with the Asheville Combined
Cycle Project at the existing Asheville Plant. There are currently four laydown areas on-site
consisting of about 16.9 -acres. However, there is a need for an additional construction laydown area
to support construction activities. The proposed 12.9 -acre project area of Construction Laydown
Area 3 is needed to provide area for storage of construction materials and equipment, and assembly
of project equipment. Construction Laydown Area 3 consists predominantly of forested areas and
some previously disturbed areas associated with past activities at the Asheville Plant. Several
jurisdictional streams (un -named tributaries to the French Broad River), wetlands, and a pond occur
within the project area. Impacts to the on-site aquatic resources will be avoided to the greatest extent
practicable; however, the project will result in permanent impacts from fill of the streams, wetlands,
and pond.
Endangered Species. On February 23, 2017, Mr. Bryan Tompkins of this office met with you and
representatives from Duke Energy and North Carolina Wildlife Resources Commission (NCWRC) to
review the project proposal. Mr. Tompkins indicated that there is potentially suitable habitat on the
site for Northern Long -Eared Bat (Myotic septentrionalis), which is currently federally listed as a
threatened species, and/or Gray Bat (Myotis grisescens), which is currently federally listed as

Mr. David Brown — US Army Corps of Engineers
2
endangered. However, several vacated residential structures occur on the site that could be used as
suitable roost sites and suitable maternity roosting habitat for Northern Long -Eared Bat does occur in
areas within the project site. For this reason, Mr. Tompkins requested that the vacated structures be
surveyed for bats and for evidence that bats have used the buildings. Surveys of the vacated
residential structures were conducted on March 24, 2017. No bats were found to be using the
structures and no physical evidence of bats using the structures was observed. Because this was the
only potentially suitable habitat for Gray Bat on the site, we concur with the assessment that the
potential for Gray Bat to occur on the site is low.
There are two separate occurrence records of northern long-eared bat within eleven miles of this
project site; however, there are no known hibemacula for Northern Long -Eared Bat species within 1/4
mile of the project area and no known maternity roosts occur within 150 -feet of the project area. For
this reason and because: 1) the project site is over 10 -miles away from the nearest known occurrence
of Northern Long -Eared Bat; and 2) there is a large amount of suitable habitat adjacent to the site and
in the surrounding area, we believe the probability of "take" that could occur from this project is
discountable. Therefore, we could concur with a "may affect, not likely to adversely affect"
determination for northern long-eared bat. We recommend that the cutting moratorium of June 1 -
July 31 be implemented into the plans if possible. Though the "not likely to adversely affect"
determination would not dependent on this action, the cutting moratorium is a measure that can be
implemented to further reduce the probability of "take" of this species.
For all other federally listed species known to occur in Buncombe County, we concur with your "no
effect" determination. For this reason and the information presented above, we believe the
requirements under section 7 of the Act are fulfilled. However, obligations under section 7 of the
Act must be reconsidered if. (1) new information reveals impacts of this identified action that may
affect listed species or critical habitat in a manner not previously considered, (2) this action is
subsequently modified in a manner that was not considered in this review, or (3) a new species is
listed or critical habitat is determined that may be affected by the identified action.
Erosion Control. The PN does not include details regarding erosion control and storm -water control
measures that will be implemented at the site. We recommend that Duke Energy develop a plan to
monitor and mitigate for erosion issues within the project area. After rain events, areas near storm
water outfall pipes or culverts that release high velocity discharges should be inspected for erosion
problems. The plan should include measures that will be implemented should erosive/mass wasting
areas be found that are contributing to sediment discharge off-site. Disturbed areas should be re-
seeded and stabilized as soon as possible. We strongly recommend that only plant species native to
the natural communities within the project area be used in association with all aspects of this project
including re -seeding of disturbed areas.
Pollinators. Throughout the site, sow native seed mixes with plant species that are beneficial to
pollinators. Taller -growing pollinator plant species should be planted along the outer edge of the
easement and anywhere on the site where mowing can be restricted during the summer months.
Taller plants, not mowed during the summer, would provide benefits to pollinators, habitat to
ground-nesting/feeding birds, and cover for small mammals. Low-growing/groundcover native
species should be planted in areas that need to be maintained. This would provide benefits to
pollinators while also minimizing the amount of maintenance, such as mowing and herbicide
treatment. Using a seed mix that includes milkweed species (milkweed is an important host plant for

Mr. David Brown — US Army Corps of Engineers
3
monarch butterflies) is especially beneficial. The following Web site provides a comprehensive list
of native plant species that benefit pollinators:
http:llwww.xerces. orglwP-contentliVloads/2014109/Mid.AtlanticPlantList web pdf
Additional information regarding plant species, seed mixes, and pollinator habitat requirements can
be provided upon request. We also offer our assistance with developing seed mixes that can be used
in conjunction with fast growing erosion control seed mix for overall soil stability and pollinator
benefits.
Mitigation. Duke Energy is proposing the following mitigation schedule for proposed impacts to
aquatic resources: 1) Impacts to 0.38 -acre of wetlands will be mitigated with a 2:1 ratio. Duke
Energy is proposing to purchase the 0.76 -acre of wetland mitigation credits from the North Carolina
Division of Mitigation Services' in -lieu fee program. 2) Of the proposed 972.5 linear feet of stream
impacts, 925.5 linear feet of stream rated "high" and 46 linear feet of stream rated "medium" using
the North Carolina Stream Assessment Methodology. Duke Energy is proposing a mitigation ratio of
2:1 for the impacts to 925.5 linear feet of "high" quality stream and a 1:1 ratio for impacts to the 46
linear feet of "medium" quality stream. As proposed, mitigation credits for the stream impacts will
be purchased from an approved private mitigation bank (3) No mitigation is proposed for the impacts
to the open water pond.
We do not object to the mitigation schedule proposed by Duke Energy and we believe the mitigation
ratios are adequate for the proposed impacts. We support the comments issued by the NCWRC and
recommend that Duke Energy explore other mitigation opportunities that are available in the
watershed. We are aware of other sites within the watershed that would provide a higher quality
mitigation than proposed and we would appreciate the opportunity to work with NCWRC and Duke
Energy to seek other mitigation options.
We appreciate the opportunity to provide these comments. If we can be of assistance or if you have
any questions, please do not hesitate to contact Mr. Bryan Tompkins of our staff at 828/258-3939,
Ext. 240. In any future correspondence concerning this project, please reference our Log Number
4-2-16-289.
Sincerely,
- - original sigma' - -
Janet Mizzi
Field Supervisor
E -Copy: Ms. Andrea Leslie, North Carolina Wildlife Resources Commission

Od North Carolina Wildlife Resources Commission 0
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 (NC)VRC) reviewed an
individual permit application to fill 0.3 8 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 0.3 8 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 Fann 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

ROY COOPER
Govei-nor
'" MICHAEL S. REGAN
�S`ecretary
S. JAY ZIMMERMAN
N-1 " Director
Water Resources
Environmental Quality
June 1, 2017
DWR # 20170426
Buncombe County
Duke Energy
Attn: Steve Cahoon
411 Fayetteville St
Raleigh NC 27601
Subject: REQUEST FOR ADDITIONAL INFORMATION
Asheville Combined Cycle Project Laydown Area
Dear Mr. Cahoon:
On April 7, 2017, the Division of Water Resources — Water Quality Programs (Division) received your
application dated March 30, 2017, requesting an Individual Water Quality Certification from the Division for
your project. The Division has determined that your application is incomplete and cannot be processed.
The application is on -hold until all of the following information is received:
1. Section 6.2.1 of the application document states that "Laydown area 3, with impacts, will provide
approximately 5.9 acres of usable area". It also states that "The proposed impacts... within Laydown
Area 3 are necessary for establishing the basin and piping, while site grading is required to provide
a suitably sized pad to accommodate laydown material and equipment. Please provide
plans/sketches that visually show the final layout of the site, including any sediment and erosion
control measures and/or post construction stormwater measures that will be required by the local
government. [15A NCAC 02H .0502(b)]
2. Please provide a detailed engineering plan, profile view, and cross-section of all proposed culverts.
These drawings must include details regarding stream alignment in relation to pipe alignment, pipe
slope, pipe burial, and any dissipater pads that may be required by the sediment and erosion
control authority. [15A NCAC 02H .0502(b)]
All work must be done "in the dry" to protect downstream water quality, therefore dewatering
methods will be necessary to temporarily dewater the stream channel and pond during pipe
installation. Please.provide a construction sequence that details the method of dewatering to be
utilized at the site and the sequence of construction events to be followed to ensure compliance
with this condition. In addition, please ensure that the location of the temporary impacts are
shown on the construction drawings and clearly indicated in the revised impact table. [15A NCAC
02H .0502(b)(3)].
State of North Carolina I Environmental Quality
450 W. Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105
Phone: [phone] FAX: [phone]

Duke Energy
DWR# 20170426
Request for Additional Information
Page 2 of 2
4. The classification of Stream 22 as "intermittent" must be verified by the Division. Please contact
Zan Price, Assistant Regional Supervisor —Asheville Regional Office, 828 296 4662 or
zan.pricencdenr.gov to schedule a site visit.
5. If the U.S. Army Corps of Engineers requests a response to any comments received as a result of
the Public Notice, please provide the Division with a copy of your response to the USACE. [15A
NCAC 02H .0502(c)]
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested information
for the proper consideration of the application. If all of the requested information is not received in writing
within 30 calendar days of receipt of this letter, the Division will be unable to approve the application and it
will be returned. The return of this project will necessitate reapplication to the Division for approval,
including a complete application package and the appropriate fee.
Please respond within 30 calendar days of receipt of this letter by submitting all of the above requested
information through this link: https:Ledocs.deg.nc.gov/FormsZSupplementa1-1nformation-Form. Please
note that the DWR# that is requested on the link is referenced above.
Please be aware that you have no authorization under the Water Quality Certification Rules for this activity
and any work done within waters of the state may be a violation of North Carolina General Statutes and
Administrative Code.
Please contact me at 336-776-9693 or Sue. [e-mail] if you have any questions or concerns.
Sincerely,
Sue Homewood
Winston-Salem Regional Office
cc: Dicky Harmon, Amec Foster Wheeler Environment & Infrastructure Inc (via email)
David Brown, USACE Asheville Regulatory Field Office (via email)
DWR ARO 401 files
DWR 401 & Buffer Permitting Unit

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
June 8, 2017
David Brown
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
Office of Archives and History
Deputy Secretary Kevin Cherry
Re: Stream Impacts for the Asheville Combined Cycle Project Construction Laydown Areas, Arden,
SAW 2014-00189, Buncombe County, ER 17-0892
Dear Mr. Brown:
We have received a public notice concerning the above project.
We have conducted a review of the project and are aware of no historic resources which would be affected
by the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-807-6579 or
environmental.review ,ncdcr. oovv. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
643( Ramona M. Bartos
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

(Sent via Electronic Mail)
Colonel Kevin P. Landers, Sr., Commander
USACE Wilmington District
69 Darlington Avenue
Wilmington, North Carolina 28403-1398
Dear Colonel Landers:
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
26313th Avenue South
St, Petersburg, Florida 33701-5505
http:llsero.nmfs.noaa.gov
71
May 10, 2017 r
,AY 2 017
.••RR•.. .............
NOAA's National Marine Fisheries Service (NMFS) reviewed the projects described in the
public notices listed below. Based on the information in the public notices, the proposed projects
would NOT occur in the vicinity of essential fish habitat (EFH) designated by the South Atlantic
Fishery Management Council, Mid -Atlantic Fishery Management Council, or the NMFS.
Present staffing levels preclude further analysis of the proposed work and no further action is
planned. This position is neither supportive of nor in opposition to authorization of the proposed
work.
Notice No. Applicant(s) Notice Date Comment Due Date
SAW -2010-01018 NCDOT 1-40 overpass May 5, 2017 June 5, 2017
at Liberty Road, STIP I-
4759
SAW -2014-00189 Duke Energy Progress May 5, 2017 June 5, 2017
LLC, Asheville CC
Project
Please note these comments do not satisfy consultation responsibilities under section 7 of the
Endangered Species Act of 1973, as amended. If an activity "may effect" listed species or critical
habitat under the purview of the NMFS, please initiate consultation with the Protected Resources
Division at the letterhead address.
Sincerely,
Pace Wilber for
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division

ENT OF yF
' F'ISII & WILDLIFE
SERVICE
a� �m United States Department of the Interior
_ FISH AND WILDLIFE SERVICE oa
�gRCH 3, Na�`9 . �y,��
Asheville Field Office "wl OF T118
160 Zillicoa Street Suite #B
Asheville, North Carolina 28801
June 6, 2017
Mr. David Brown
Asheville Regulatory Field Office
U.S. Army Corps of Engineers
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
Dear Mr. Brown:
This is the report of the U.S. Fish and Wildlife Service (USFWS) and the Department of the Interior
on the U.S. Army Corps of Engineers' (Corps) Public Notice (PN) of an Individual Permit
Application (IPA) submitted by Mr. Wayne Smith of Duke Energy Carolinas, LLC (Duke Energy) to
impact about 972.5 linear feet of stream impacts, 0.87 -acres of permanent open water impacts, and
0.38 -acres of permanent wetland impacts associated with the Construction Laydown Areas at the
proposed Asheville Combined Cycle Plant Project, in Buncombe County, North Carolina.
Information for this report is based on information obtained by our staff at a scoping meeting held on
February 23, 2017, and a review of the PN issued by the Corps. The report is submitted in
accordance with the provisions of the National Environmental Policy Act; 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).
According to the information presented, the proposed project consists of clearing and preparing a
construction laydown area (Construction Laydown Area 3) associated with the Asheville Combined
Cycle Project at the existing Asheville Plant. There are currently four laydown areas on-site
consisting of about 16.9 -acres. However, there is a need for an additional construction laydown area
to support construction activities. The proposed 12.9 -acre project area of Construction Laydown
Area 3 is needed to provide area for storage of construction materials and equipment, and assembly
of project equipment. Construction Laydown Area 3 consists predominantly of forested areas and
some previously disturbed areas associated with past activities at the Asheville Plant. Several
jurisdictional streams (un -named tributaries to the French Broad River), wetlands, and a pond occur
within the project area. Impacts to the on-site aquatic resources will be avoided to the greatest extent
practicable; however, the project will result in permanent impacts from fill of the streams, wetlands,
and pond.
Endangered Species. On February 23, 2017, Mr. Bryan Tompkins of this office met with you and
representatives from Duke Energy and North Carolina Wildlife Resources Commission (NCWRC) to
review the project proposal. Mr. Tompkins indicated that there is potentially suitable habitat on the
site for Northern Long -Eared Bat (Myotic septentrionalis), which is currently federally listed as a
threatened species, and/or Gray Bat (Myotis grisescens), which is currently federally listed as

Mr. David Brown — US Army Corps of Engineers
2
endangered. However, several vacated residential structures occur on the site that could be used as
suitable roost sites and suitable maternity roosting habitat for Northern Long -Eared Bat does occur in
areas within the project site. For this reason, Mr. Tompkins requested that the vacated structures be
surveyed for bats and for evidence that bats have used the buildings. Surveys of the vacated
residential structures were conducted on March 24, 2017. No bats were found to be using the
structures and no physical evidence of bats using the structures was observed. Because this was the
only potentially suitable habitat for Gray Bat on the site, we concur with the assessment that the
potential for Gray Bat to occur on the site is low.
There are two separate occurrence records of northern long-eared bat within eleven miles of this
project site; however, there are no known hibemacula for Northern Long -Eared Bat species within 1/4
mile of the project area and no known maternity roosts occur within 150 -feet of the project area. For
this reason and because: 1) the project site is over 10 -miles away from the nearest known occurrence
of Northern Long -Eared Bat; and 2) there is a large amount of suitable habitat adjacent to the site and
in the surrounding area, we believe the probability of "take" that could occur from this project is
discountable. Therefore, we could concur with a "may affect, not likely to adversely affect"
determination for northern long-eared bat. We recommend that the cutting moratorium of June 1 -
July 31 be implemented into the plans if possible. Though the "not likely to adversely affect"
determination would not dependent on this action, the cutting moratorium is a measure that can be
implemented to further reduce the probability of "take" of this species.
For all other federally listed species known to occur in Buncombe County, we concur with your "no
effect" determination. For this reason and the information presented above, we believe the
requirements under section 7 of the Act are fulfilled. However, obligations under section 7 of the
Act must be reconsidered if. (1) new information reveals impacts of this identified action that may
affect listed species or critical habitat in a manner not previously considered, (2) this action is
subsequently modified in a manner that was not considered in this review, or (3) a new species is
listed or critical habitat is determined that may be affected by the identified action.
Erosion Control. The PN does not include details regarding erosion control and storm -water control
measures that will be implemented at the site. We recommend that Duke Energy develop a plan to
monitor and mitigate for erosion issues within the project area. After rain events, areas near storm
water outfall pipes or culverts that release high velocity discharges should be inspected for erosion
problems. The plan should include measures that will be implemented should erosive/mass wasting
areas be found that are contributing to sediment discharge off-site. Disturbed areas should be re-
seeded and stabilized as soon as possible. We strongly recommend that only plant species native to
the natural communities within the project area be used in association with all aspects of this project
including re -seeding of disturbed areas.
Pollinators. Throughout the site, sow native seed mixes with plant species that are beneficial to
pollinators. Taller -growing pollinator plant species should be planted along the outer edge of the
easement and anywhere on the site where mowing can be restricted during the summer months.
Taller plants, not mowed during the summer, would provide benefits to pollinators, habitat to
ground-nesting/feeding birds, and cover for small mammals. Low-growing/groundcover native
species should be planted in areas that need to be maintained. This would provide benefits to
pollinators while also minimizing the amount of maintenance, such as mowing and herbicide
treatment. Using a seed mix that includes milkweed species (milkweed is an important host plant for

Mr. David Brown — US Army Corps of Engineers
3
monarch butterflies) is especially beneficial. The following Web site provides a comprehensive list
of native plant species that benefit pollinators:
http:llwww.xerces. orglwP-contentliVloads/2014109/Mid.AtlanticPlantList web pdf
Additional information regarding plant species, seed mixes, and pollinator habitat requirements can
be provided upon request. We also offer our assistance with developing seed mixes that can be used
in conjunction with fast growing erosion control seed mix for overall soil stability and pollinator
benefits.
Mitigation. Duke Energy is proposing the following mitigation schedule for proposed impacts to
aquatic resources: 1) Impacts to 0.38 -acre of wetlands will be mitigated with a 2:1 ratio. Duke
Energy is proposing to purchase the 0.76 -acre of wetland mitigation credits from the North Carolina
Division of Mitigation Services' in -lieu fee program. 2) Of the proposed 972.5 linear feet of stream
impacts, 925.5 linear feet of stream rated "high" and 46 linear feet of stream rated "medium" using
the North Carolina Stream Assessment Methodology. Duke Energy is proposing a mitigation ratio of
2:1 for the impacts to 925.5 linear feet of "high" quality stream and a 1:1 ratio for impacts to the 46
linear feet of "medium" quality stream. As proposed, mitigation credits for the stream impacts will
be purchased from an approved private mitigation bank (3) No mitigation is proposed for the impacts
to the open water pond.
We do not object to the mitigation schedule proposed by Duke Energy and we believe the mitigation
ratios are adequate for the proposed impacts. We support the comments issued by the NCWRC and
recommend that Duke Energy explore other mitigation opportunities that are available in the
watershed. We are aware of other sites within the watershed that would provide a higher quality
mitigation than proposed and we would appreciate the opportunity to work with NCWRC and Duke
Energy to seek other mitigation options.
We appreciate the opportunity to provide these comments. If we can be of assistance or if you have
any questions, please do not hesitate to contact Mr. Bryan Tompkins of our staff at 828/258-3939,
Ext. 240. In any future correspondence concerning this project, please reference our Log Number
4-2-16-289.
Sincerely,
- - original sigma' - -
Janet Mizzi
Field Supervisor
E -Copy: Ms. Andrea Leslie, North Carolina Wildlife Resources Commission

Od North Carolina Wildlife Resources Commission 0
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 (NC)VRC) reviewed an
individual permit application to fill 0.3 8 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 0.3 8 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 Fann 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

ROY COOPER
Govei-nor
'" MICHAEL S. REGAN
�S`ecretary
S. JAY ZIMMERMAN
N-1 " Director
Water Resources
Environmental Quality
June 1, 2017
DWR # 20170426
Buncombe County
Duke Energy
Attn: Steve Cahoon
411 Fayetteville St
Raleigh NC 27601
Subject: REQUEST FOR ADDITIONAL INFORMATION
Asheville Combined Cycle Project Laydown Area
Dear Mr. Cahoon:
On April 7, 2017, the Division of Water Resources — Water Quality Programs (Division) received your
application dated March 30, 2017, requesting an Individual Water Quality Certification from the Division for
your project. The Division has determined that your application is incomplete and cannot be processed.
The application is on -hold until all of the following information is received:
1. Section 6.2.1 of the application document states that "Laydown area 3, with impacts, will provide
approximately 5.9 acres of usable area". It also states that "The proposed impacts... within Laydown
Area 3 are necessary for establishing the basin and piping, while site grading is required to provide
a suitably sized pad to accommodate laydown material and equipment. Please provide
plans/sketches that visually show the final layout of the site, including any sediment and erosion
control measures and/or post construction stormwater measures that will be required by the local
government. [15A NCAC 02H .0502(b)]
2. Please provide a detailed engineering plan, profile view, and cross-section of all proposed culverts.
These drawings must include details regarding stream alignment in relation to pipe alignment, pipe
slope, pipe burial, and any dissipater pads that may be required by the sediment and erosion
control authority. [15A NCAC 02H .0502(b)]
All work must be done "in the dry" to protect downstream water quality, therefore dewatering
methods will be necessary to temporarily dewater the stream channel and pond during pipe
installation. Please.provide a construction sequence that details the method of dewatering to be
utilized at the site and the sequence of construction events to be followed to ensure compliance
with this condition. In addition, please ensure that the location of the temporary impacts are
shown on the construction drawings and clearly indicated in the revised impact table. [15A NCAC
02H .0502(b)(3)].
State of North Carolina I Environmental Quality
450 W. Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105
Phone: [phone] FAX: [phone]

Duke Energy
DWR# 20170426
Request for Additional Information
Page 2 of 2
4. The classification of Stream 22 as "intermittent" must be verified by the Division. Please contact
Zan Price, Assistant Regional Supervisor —Asheville Regional Office, 828 296 4662 or
zan.pricencdenr.gov to schedule a site visit.
5. If the U.S. Army Corps of Engineers requests a response to any comments received as a result of
the Public Notice, please provide the Division with a copy of your response to the USACE. [15A
NCAC 02H .0502(c)]
Pursuant to Title 15A NCAC 02H .0502(e), the applicant shall furnish all of the above requested information
for the proper consideration of the application. If all of the requested information is not received in writing
within 30 calendar days of receipt of this letter, the Division will be unable to approve the application and it
will be returned. The return of this project will necessitate reapplication to the Division for approval,
including a complete application package and the appropriate fee.
Please respond within 30 calendar days of receipt of this letter by submitting all of the above requested
information through this link: https:Ledocs.deg.nc.gov/FormsZSupplementa1-1nformation-Form. Please
note that the DWR# that is requested on the link is referenced above.
Please be aware that you have no authorization under the Water Quality Certification Rules for this activity
and any work done within waters of the state may be a violation of North Carolina General Statutes and
Administrative Code.
Please contact me at 336-776-9693 or Sue. [e-mail] if you have any questions or concerns.
Sincerely,
Sue Homewood
Winston-Salem Regional Office
cc: Dicky Harmon, Amec Foster Wheeler Environment & Infrastructure Inc (via email)
David Brown, USACE Asheville Regulatory Field Office (via email)
DWR ARO 401 files
DWR 401 & Buffer Permitting Unit

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
June 8, 2017
David Brown
Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
Office of Archives and History
Deputy Secretary Kevin Cherry
Re: Stream Impacts for the Asheville Combined Cycle Project Construction Laydown Areas, Arden,
SAW 2014-00189, Buncombe County, ER 17-0892
Dear Mr. Brown:
We have received a public notice concerning the above project.
We have conducted a review of the project and are aware of no historic resources which would be affected
by the project. Therefore, we have no comment on the project as proposed.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-807-6579 or
environmental.review ,ncdcr. oovv. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
643( Ramona M. Bartos
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599