20071505 Ver 5_WRC Comments_20170508

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
May 8, 2017
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: McElrath Carolina Investments
UTs to Willow Creek, Henderson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to address impacts to several unnamed tributaries (UTs) to Willow Creek in
Henderson County. I visited the site with other agency representatives on January 19, 2017. 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 observance of a trout moratorium is not
required.
The project involves the removal of three HDPE culverts on two streams, including a 155 ft
culvert and 200 ft culvert on "UT1", and a 489 ft culvert on "UT2". Portions of these culverts
would be used to culvert 20 ft of both UT 1 and UT2. All portions of stream that would be
daylighted would be restored via bank sloping, benching, and planting. Culvert removal and
restoration activities would be performed in the dry on UT1; it is unclear if work on UT2 will
also be performed in the dry.
Sediment impacts from previous activities were identified on the property. Notable in -stream
sediment was noted on numerous UTs to Willow Creek. Sediment removal is recommended by
the applicant on 104 ft of two UTs to Willow Creek; identified sediment sources are a dam
failure and a culvert failure. The applicant proposes to remove excess sediment from these
reaches via shovel and bucket. Photos included in the application reveal a vertical eroded bank
at the culvert failure location, but it is unclear if the dam failure is a continuing source of
instability and sediment to the stream.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

McElrath Carolina Investments
UTs to Willow Creek, Henderson County
May 8, 2017
We offer the following recommendations to minimize impacts to terrestrial and aquatic resources
from the project:
1. Project activities should be accomplished as quickly as possible and vigilance used in
sediment and erosion control during site preparation, construction, and clean up. Culvert
removal and restoration activities should be performed in the dry.
2. According to C1earWater Environmental staff, the planted buffer will be at least 5 ft wide on
each bank. It appears that a buffer of at least 25 ft was protected on other streams on the
property. We recommend that a woody buffer of at least 30 feet be planted on both sides of
the stream to ensure project success. A wide forested buffer can ensure greater bank
stability, filter overland pollutants, and provide habitat for birds and other wildlife.
3. If the dam failure and culvert failure sites are contributing to continuing instability and
sedimentation, we recommend that these areas be stabilized.
4. The application proposes reusing HDPE culvert. We recommend against using slick -walled
HDPE material, as this material is less likely to hold stream substrate and provide for
movement of aquatic organisms like fish and salamanders.
5. Disturbed areas should be seeded, mulched and/or matted as soon as possible. Any erosion
control matting used should be free of plastic or nylon mesh, 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: Clement Riddle, C1earWater Environmental
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service