20220138 Ver 1_WRC Comments_20220310

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
March 10, 2022
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Rich Mountain Subdivision
UTs to Featherstone Creek, Henderson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert 146 ft of unnamed tributaries (UTs) to Featherstone Creek in Henderson
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).
Wild trout reproduction should not be impacted by project activities, and a trout moratorium does
not apply.
Stream impacts are associated with an access road to a proposed low density residential
development. High density polyethylene (HDPE) culverts are proposed for four stream
crossings. We recommend against HDPE, as this smooth material is less likely to hold stream
substrate and provide for movement of aquatic organisms like fish and salamanders. Three of
four of the culverts will have a slope of at least 5%, and the application proposes not to bury
these culverts but instead to keep them level with the grade of the slope and the outlet flush with
the stream. We agree that culvert burial is not needed for these culverts, and we stress that
maintaining stability at the inlet and outlet is most important. To avoid scour and perch
development for these steep culverts, we recommend adding some larger stone to backfill short
channel reaches in front of inlets and below outlets. This stone should be set into the bed to
minimize changing the bed elevation and top -dressed with native material if possible.
We offer the following recommendations to minimize impacts to fish and wildlife:
1. In -channel work should be accomplished as quickly as possible and vigilance used in
sediment and erosion control during site preparation, construction, and clean up. Disturbed
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Rich Mountain Subdivision Page 2 March 10, 2022
UTs Featherstone Cr, Henderson Co.
areas should be seeded, mulched and/or matted as soon as possible, preferably at the end of
each work day. A native riparian seed mix and native shrubs and trees should be used to
permanently stabilize disturbed stream areas.
2. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
mesh frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last
for years.
3. The proposed culverts are HDPE material. We recommend against using RCP or HDPE
material, as this material is less likely to hold stream substrate and provide for movement of
aquatic organisms like fish and salamanders.
4. Ensure that steep culverts do not result in channel erosion or culvert perch. This can be
accomplished by installing larger stone at the inlet and outlet of the culverts, embedding the
material into the stream bed so that the bed elevation change is minimized.
5. We recommend maintaining a buffer of at least 30 ft on the stream to provide shade and
ensure streambank stability.
6. Limit native vegetation clearing as much as possible. Maintain open space areas with native
vegetation and maintain the undeveloped area to the north as a forested green space.
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: Jeff Golladay, Clearwater Environmental
Andrew Moore, NC Division of Water Resources