20170767 Ver 1_WRC Comments_20170721

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
July 21, 2017

Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: Middle Fork Baptist Church Culvert
UT Middle Fork French Broad River, Transylvania County

Dear Mr. Brown:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert up to 149 feet of an unnamed tributary (UT) to Middle Fork French Broad
River in Transylvania 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).

There are Brown Trout and Rainbow Trout in the Middle Fork French Broad River, and project
activities should be avoided during the period of October 15 to April 15. In addition, the French
Broad River downstream of the project supports Eastern Hellbender \[Cryptobranchus
alleganiensis, US Federal Species of Concern (FSC), NC SC (Special Concern)\] and French
Broad River Crayfish (Cambarus reburrus, US FSC, NC Significantly Rare). Both trout and
these rare species are especially sensitive to excess sediment.

The application proposes to install two HDPE culverts and a drop box to allow pedestrian access
to the backside of a church and allow children safe access to a playground area. The playground
area is currently accessed from the parking lot with a small walking bridge. The stream is small
and banks appear stable. We recommend against culverting the stream for the reasons stated in
the application, and we suggest that the applicant employ other options, such as a bridge across
the stream to access the church and a fence between the stream and the playground, to achieve
the goals of the project.

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Middle Fork Baptist Church Culvert Page 2 July 21, 2017
UT Middle Fork French Broad, Transylvania County
If the project is permitted, 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. 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.
3. We recommend against using smooth‐walled HDPE material, as this slick material is less
likely to hold stream substrate and provide for movement of aquatic organisms like fish and
salamanders.
4. Project activities should be avoided between October 15 and April 15 to avoid impacts to
Brown Trout spawning.

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: Andy Mull, Middle Fork Baptist Church
Kevin Mitchell, NC Division of Water Resources