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Home My WebLink About20180612 Ver 1_Comments and Request for Addtional Info_20180627/ DEPARTMENT OF THE ARMY WILMINGTON DISTRICT, CORPS OF ENGINEERS 151 PATTON AVENUE 9 ROOM 208 ASHEVILLE, NORTH CAROLINA 28801-5006 June 27, 2018 Action ID: SAW -2015-00263 Clearwater Environmental Consultants, Inc. Attn.: Clement Riddle 32 Clayton Road Asheville, NC 28801 Subject: Corps Comments and Request for Additional Information— WCU 2014 Master Plan Improvements Project Dear Mr. Riddle: Reference is made to your May 1, 2018, Department of the Army (DA) permit application, submitted on behalf of Western Carolina University (WCU) for the WCU 2014 Master Plan Improvements Project in Cullowhee, Jackson County, North Carolina. Based on our review of the application, supporting documents, and comments submitted by supporting agencies and the public, the Corps is requesting additional information and providing comments as follows: 1. The Corps has reviewed and evaluated the applicants proposed compensatory mitigation ratio of 1:1 for unavoidable stream and wetland impacts which result in a loss of associated waters of the U.S. (WoUS). Compensatory mitigation will be required at a 2:1 ratio for stream impacts and 1.5:1 for wetland impacts. The applicant has proposed compensatory mitigation will be in the form of payment into the state's in -lieu fee program administered by the N.C. Division of Mitigation Services (DMS). Therefore, for the 500 linear feet of unavoidable stream impacts the applicant is to obtain 1,000 linear feet of cold water stream credits and for the 0.383 acres of unavoidable wetlands impacts the applicant is to obtain 0.57 acres of riparian wetland credits in the Tuckasegee River Basin (Little Tennessee HUC 06010203) from DMS. The applicant may revise the proposed mitigation plan submitted with the permit application. If so, provide the Corps and N.C. Division of Water Resources (DWR) a revised mitigation plan explaining how the applicant will provide compensatory mitigation at the ratios noted above. 2. Per comments from the U.S. Fish and Wildlife Service (USFWS), in order to minimize impacts to the federally listed endangered species Appalachian elktoe (Alasmidonta raveneliana) the following special condition is intended to be included in issuance of the permit: Measures to control sediment and erosion shall be installed before any ground - disturbing activities occur. Grading and backfilling shall be minimized, and existing native vegetation shall be retained (wherever possible) to maintain riparian cover. Disturbed areas shall be revegetated with native grass and tree species as soon as work within the stream is completed. Ground disturbance shall be limited to what will be stabilized (via mulch, matting, etc.) by the end of the workday. Natural fiber matting (coir, etc.) shall be used for erosion control as synthetic netting can trap animals and persist in the environment beyond its intended purpose. 3. Per comments from N.C. State Historic Preservation Office (SHPO), the Corps request a comprehensive archeological survey be conducted by an experienced archaeologist to identify and evaluate the significance of archaeological remains that may be damaged or destroyed by the proposed interinural field improvements portion of the project. The area for the survey at this project site is shown on the attached figure as "Approximate Area Corps of Engineers Permit Area for Section 106 Review." This request is necessary in order to comply with requirements under Section 106 of the National Historic Preservation Act (NHPA) for issuance of this federal permit. The applicant is to provide two copies and one digital copy of the resulting archaeological survey report, as well as two copies of the appropriate site forms to the Corps and the same to SHPO per their letter. Submit this report to the agencies by December 31, 2018. Based upon the findings of the survey, the Corps may need to forward a copy of the report to the Eastern Band of Cherokee Indians (EBCI) Tribal Historic Preservation Office (THPO) for review and comment. Do note, prior to conducting the archeological survey the principal investigator for the archeological survey will need to apply for a permit in accordance with the North Carolina Archaeological Resources Protection Act (ARPA) since the project is on state-owned or controlled property. 4. The applicant is to copy the Corps in their responses/submittals to the request for additional information from DWR. At this time, the application is on hold until the above additional information has been received. Once the Corps receives the information we will be able to continue to process your application. If you have any questions please contact me. ji)ncerely, �I avid Brown, PG Regulatory Specialist/Geologist Asheville Regulatory Field Office Copy: USFWS Attn.: Byron Hamstead 160 Zillicoa Street Asheville, NC 28801 NCDEQ-DWR Attn.: Kevin Mitchell 2090 U.S. Highway 70 Swannanoa, NC 28778 NCDEQ-DWR Attn.: Sue Homewood 450 W. Hanes Mill Road, Suite 300 Winston Salem, NC 27105 NCWRC Attn.: Andrea Leslie 645 Fish Hatchery Road Marion, NC 28752 NCDNCR-SHPO Attn.: Renee Gledhill -Earley 4617 Mail Service Center Raleigh, NC 27699-4617 NCDNCR-Western Office Attn.: Linda Hall 176 Riceville Road Asheville, NC 28805 7 WCU Master Plan Improvements i 6 -- f 46 • �.— fiver ` -- e Cullowhee Creek loft r +! �' Tuckasegee � River to` • l Intramural Fields , , 4qbb` xr EST R til io r s 1 sun 21 field • r I� 4 � o ti� • WE sr s N Legend Streams �_______� ' ♦ 0 500 1,000 2,000 Intramural Fields • ;�� • Feet Drawn -by: AK 4 17. 8;'CEC Proledt# 706 _ - "" , •� = i , L ; }Cop i ht. 2 , l'VaGi:onal Geo�Wph, ;S iefy' �_ - 1 - Jackson County, CLearWaLer USGS Topographic Map North Carolina Sylva South Quad 32 Clayton Street Asheville, North Carolina 28801 Figure 2 WCU Intramural Fields (+/- 10 AC) I „—' I ' .♦ — iii L �� `\ , � � yi -/• / y . I rid ! -_- - __�_ \'/ . ♦ t \./,moi Al 1 .fir : ''�` • ,,- -, Proposed Fill .A, {• I. w. 0.04 AC Approximate Areas of Corps of Engineers Permit Area for Section 106 Review The Permit Area for Section 106 Review is defined as the proposed fill area of the jurisdictional wetlands and extends `t Proposed Fill approximately 150 feet.00 ! . out from the boundary of ,I,. 0.05 AC , the jurisdcational wetlands. iAL V • Le9 end Proposed Wetland Impacts (0.09 AC) - i Wetland Avoided 0.34 AC 7 Linear Wetland ' I 0 37.5 75 150 , Culvert �Feet Drawn by: AKT 4.4.201 ClEf Project# 79 !KC'C:e;n, Cer'for G'eograp'hlic,ll'nfonrpafioh &'Ahalysis Jackson Count CLearWaLer Impact Ma Y- P P North Carolina Figure 5.3 224 South Grove Street, Suite F Hendersonville, North Carolina 28792