20190189 Ver 2_WRC Comments_20190402

❑ North Carolina Wildlife Resources Commission ❑
Gordon Myers, Executive Director
April 2, 2019
Ms. Amanda Fuemmeler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Lance Road Subdivision — Bridge Construction
Avery Creek, Buncombe County
Dear Ms. Fuemmeler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to replace a triple box culvert with a bridge with 3 center columns, impacting 80 ft2
of Avery Creek in Buncombe County. This application is the second application for impacts for
this project; our comments on the first project were submitted on March 7, 2019. Our comments
on the current 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).
Wild trout reproduction should not be impacted by this project and a trout moratorium is not
needed. However, French Broad River Crayfish (Cambarus reburrus, NC Significantly Rare) is
found in Avery Creek.
The application proposes to remove a triple box culvert and construct a bridge in its place. A
concrete footer for a triple column structure would be poured in place within the stream bed, and
this work would be done in the dry using impervious dikes and bypass pumping.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Work should be accomplished as quickly as possible and vigilance used in sediment and
erosion control during site preparation, construction, and clean up. Disturbed areas should be
seeded, mulched and matted as soon as possible, preferably at the end of each work day.
2. Concrete must be allowed to fully cure in the dry; full cure time will take at least 24 hours.
Contact between wet concrete and the stream can result in dangerously high in -stream pH
levels.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Lance Road Subdivision - Bridge Page 2 April 2, 2019
Avery Cr, Buncombe County
3. The application proposes to use biodegradable turf reinforcement matting; this matting must
be free of all plastic or nylon filaments, as this type of mesh netting frequently entangles
wildlife and is slow to degrade, resulting in a hazard that may last for years.
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: Mike Lovoy, Advantage Civil Engineering
Zan Price, NC Division of Water Resources