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HomeMy WebLinkAbout20181446 Ver 1_WRCComments_201812119 North Carolina Wildlife Resources Commission 0 Gordon Myers, Executive Director December 11, 2018 Ms. Amanda Fuemmeler U.S. Army Corps of Engineers, Regulatory Branch 151 Patton Avenue, Room 208 Asheville, North Carolina 28801-5006 SUBJECT: City of Asheville North Fork Water Line Project North Fork Swannanoa River, UT, and wetlands, Buncombe County Dear Ms. Fuemmeler: Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an application to impact 5 wetlands, entailing 0.17 acre of permanent and 0.29 acre of temporary impacts, and impact 2 stream sites, entailing 105 ft of temporary impact on the North Fork Swannanoa River and an unnamed tributary (UT), all for a water line project 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 will not impact wild trout, and project activities do not need to be avoided during a trout moratorium. The construction corridor will be 45 ft wide, and a permanently maintained right-of-way (ROW) will be 20 ft wide in stream and wetland areas and 24 ft wide in upland areas. The water line will parallel the North Fork of the Swannanoa River for 1,290 ft, and in some locations, it is perhaps 10 ft from the river bank. We recommend that the ROW be narrowed to 20 ft where it is within 30 ft of the river. We also ask that the City plant native woody species within the construction corridor that will not be permanent ROW that is within 30 ft of the North Fork of the Swannanoa River. In addition, we ask that the City plant the permanent ROW that is parallel to the river in native riparian seed mix. The water line will be installed though wetlands and streams with the trench cut method. Trench cuts through streams will be performed in the dry. Riprap would be used in the bed and on the banks of the North Fork Swannanoa River at the site of trenching in order to ensure stability, as flows within the river are extremely variable, dependent on reservoir releases. We recommend the use of livestakes in addition to riprap on the banks. Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 North Fork Water Line Page 2 December 11, 2018 N. Fork Swannanoa, Buncombe Co Wetland top soils will be stored and replaced as top soil within the trenches that run through wetlands. All wetland work will be performed from wetland mats. Native wetland seed mix will be used in disturbed wetland areas. Mitigation of 1:1 is proposed for permanent impacts to wetlands, which consist of shifting wetlands from forested to herbaceous. In wetland areas, we recommend that the applicant mark the construction corridor clearly in the wetland, fencing/taping the non- impact area and ensuring construction equipment will be kept out of this area. We offer the following recommendations to minimize impacts to fish and wildlife resources: 1. Avoid equipment maintenance in the immediate vicinity of streams and wetlands, make stream crossings as narrow as possible, minimize stream bank disturbance, avoid spraying of herbicides, and where woody vegetation is cleared, cut so that stumps can resprout. 2. Sediment and erosion controls measures should be installed prior to any land clearing or construction. 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. 3. For forested wetlands, any area outside the maintenance right-of-way (ROW) should be replanted with native woody species. 4. Within wetlands, mark the construction corridor clearly in the wetland, fencing/taping the non- impact area and ensuring construction equipment will be kept out of this area. 5. For the UT to the North Fork Swannanoa River, the top 6-12 inches of stream substrate should be stockpiled, kept saturated during pipe installation, and replaced once the pipe is installed. 6. We recommend that the native riparian mix be applied within the permanent ROW that parallels the North Fork Swannanoa River. 7. We recommend that the ROW be narrowed to 20 ft where it is within 30 ft of the river. We also ask that the City plant native woody species within the construction corridor that will not be permanent ROW that is within 30 ft of the North Fork of the Swannanoa River. 8. Matting used for stabilization should be free of nylon or plastic mesh, as this type of netting frequently entangles wildlife and is slow to degrade resulting in a hazard that may last for years. 9. ROW maintenance on stream banks should be performed by hand, cutting woody vegetation to allow resprouting. ROW maintenance through wetlands should also be done by hand, avoiding the use of heavy machinery. If heavy machinery is used in wetlands, wetland mats should be used. Thank you for the opportunity to review and comment on this project. Please contact me at (828) 803-6054 if you have any questions about these comments. Sincerely, �o�zd-Cx� Andrea Leslie Mountain Region Coordinator, Habitat Conservation Program ec: Jon Swaim, McGill Associates Zan Price, NC Division of Water Resources Allen Ratzlaff, US Fish and Wildlife Service