20180779 Ver 1_WRC Comments_20180628

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
June 28, 2018
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Avadim Project
Wetlands near Swannanoa River, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 0.217 acre of wetland and temporarily impact 0.049 acre of
wetland near the Swannanoa River in Buncombe County. 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).
Project activities should not impact wild trout and do not need to be avoided during the trout
moratorium. However, the project site is less than 500 ft from the Swannanoa River, which has
both Rainbow Trout and Eastern Hellbender (Cryptobranchus alleganiensis, US Federal Species
of Concern, NC Special Concern), both of which are especially sensitive to sediment, and
excellent erosion and sediment control is essential to minimize impacts to these species.
The application proposes to fill 0.217 acre of wetland for the construction of a parking lot
associated with Avadim's corporate headquarters and associated infrastructure. Currently 0.27
acre of wetland mitigation through the NC Division of Mitigation Services is proposed, which a
1.2:1 ratio. There is no justification for this ratio provided, and we recommend that mitigation be
provided at a 2:1 ratio.
A stormwater management plan is in review, and it involves the use of underground storm cells
and two level spreaders that will release water to upland locations. 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
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Avadim Project Page 2 June 28, 2018
Wetlands near Swannanoa, Buncombe County
avoided. As stormwater runoff from pavement can cause short-term temperature spikes in
downstream waters and the Swannanoa River hosts coldwater species, mechanisms to lower
stormwater temperature should be incorporated into the stormwater management design.
Sediment and erosion control measures should be installed prior to any land clearing or
construction. The use of biodegradable and wildlife -friendly sediment and erosion control
devices is strongly recommended. Silt fencing, fiber rolls and/or other products should have
loose -weave netting that is made of natural fiber materials with movable joints between the
vertical and horizontal twines. Silt fencing that has been reinforced with plastic or metal mesh
should be avoided as it impedes the movement of terrestrial wildlife species. These measures
should be routinely inspected and properly maintained. Excessive silt and sediment loads can
have numerous detrimental effects on aquatic resources including destruction of spawning
habitat, suffocation of eggs, and clogging of gills of aquatic species.
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: Alan Moore, Nutter and Associates
Zan Price, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service