20180612 Ver 1 _WRCComments _20180615

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
June 15, 2018
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Western Carolina University 2014 Master Plan Improvements
UT to Cullowhee Creek and wetlands, Jackson County
SAW -2015-00263
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the
individual 404 permit application for Western Carolina University 2014 Master Plan
Improvements project, which would impact 0.383 acre of wetland and 500 ft of an unnamed
tributary (UT) to Cullowhee Creek in Jackson County. NCWRC visited the site on March 20,
2018. 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).
Western Carolina University intends on constructing a parking lot, culverting 500 ft of UT
Cullowhee Creek and filling 0.293 acre of wetland, and improving its existing soccer field,
filling 0.09 acre of wetland. The parking lot would be constructed on fill, and the stream
culverted with a 60 -inch reinforced concrete pipe. Underground stormwater treatment is
proposed, but no details are provided.
Project activities should not impact wild trout reproduction, and a moratorium is not needed.
However, Cullowhee Creek is part of the Tuckasegee River Aquatic Habitat, a natural area rated
Exceptional by the NC Natural Heritage Program due to the richness of rare species it contains.
Near the project, Cullowhee Creek and the Tuckasegee River support a number of listed and rare
aquatic species, including the Sicklefin Redhorse (Moxostoma sp., US Candidate, NC
Threatened), Eastern Hellbender [Cryptobranchus alleganiensis, US Federal Species of Concern
(FSC), NC SC (Special Concern)], Little Tennessee Crayfish (Cambarus georgiae, US FSC, NC
SC), and French Broad River Crayfish (Cambarus reburrus, US FSC, NC Significantly Rare).
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

WCU 2014 Master Plan Improvements Page 2 June 15, 2018
UT Cullowhee Cr, Jackson County
We offer the following comments and recommendations on this project:
It is extremely important that excellent erosion and sediment control be used during site
staging, construction, and cleanup to protect downstream Cullowhee Creek and Tuckasegee
River.
To protect the rare and listed species in the Tuckasegee River, we request the use of
sediment and erosion control practices outlined in the Design Standards in Sensitive
Watersheds (15A NCAC 4B .0124). In addition, disturbed areas should be seeded,
mulched and/or matted as soon as possible, preferably at the end of each work day; at
a minimum, disturbed areas should be stabilized within five working days or seven
calendar days, whichever is shorter.
Instream work should be performed in the dry and water routed around the work area.
Matting used on site should be free of nylon or plastic mesh; this type of mesh netting
frequently entangles wildlife and is slow to degrade, resulting in a hazard lasting for
years.
A mitigation ratio of 1:1 is proposed for wetland and stream impacts. NCWAM and
NCSAM scores for the wetlands were Medium. The proposed stream and wetland impacts
are especially concerning due to their proximity to the Tuckasegee River; and NCWRC
recommends that a higher ratio of 2:1 be used for stream and wetland impacts for this
project.
Effective stormwater management is essential in minimizing impacts to downstream waters.
Stormwater control measures should mimic the hydrograph consistent with an impervious
coverage of less than 10%. We recommend the use of Low Impact Design techniques, such
as grassed swales and pervious pavement; curb and gutter, catch basins, and underground
piping of stormwater should be avoided. As stormwater runoff from pavement can cause
short-term temperature spikes in downstream waters, mechanisms to lower stormwater
temperature should be incorporated into the stormwater management design.
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: Clement Riddle, C1earWater Environmental Consultants
Kevin Mitchell & Sue Homewood, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Amanda Bushon, NCWRC