20191432 Ver 1_WRC Comments_20191205

❑ North Carolina Wildlife Resources Commission ❑
Gordon Myers, Executive Director
December 5, 2019
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Rivercane Industrial Project
UT to Cane Creek and wetlands, Henderson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to fill 0.09 acre of wetland, permanently impact 130 ft of an unnamed tributary (UT)
to Cane Creek with a culvert, and temporarily impact 60 ft of UTs to Cane Creek for two
culverts and a sewer/water line crossing 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).
Project activities will not impact wild trout and a moratorium is not needed for the project. In the
vicinity of the project, Cane Creek does support Blotched Chub (Erimystax insignis, NC
Significantly Rare), and effective erosion and sediment control measures are needed to minimize
sediment impacts to this species.
The site plan involves the construction of a 276,000 ft2 industrial building, roads, and stormwater
infrastructure. The entire project will be in the 100-year floodplain. The NCWRC does not
support commercial or residential development within the 100-year floodplain. The filling of
floodplains increases the potential for flooding and degrades in -stream habitats for fish and other
aquatic organisms.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Use stormwater control measures to mimic the hydrograph consistent with an impervious
coverage of less than 10%. As stormwater runoff from pavement can cause short-term
temperature spikes in downstream waters, mechanisms to lower stormwater temperature
should be incorporated into the stormwater management design.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Rivercane Industrial Page 2 December 5, 2019
UT Cane Cr, Henderson Co
2. Work should be accomplished as quickly as possible and vigilance used in sediment and
erosion control during site preparation, construction, and clean up.
3. 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.
4. The application proposes using a 130-ft 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. Stream channels at the utility crossing and temporary culvert locations should be restored to
near pre -disturbance conditions. Banks should be stabilized with a seed mix that includes a
quick -growing temporary seed and native riparian vegetation. Native woody vegetation,
such as live stakes, should also be planted.
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,
zoy,'J�
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Anna Priest, C1earWater Environmental
Andrew Moore, NC Division of Water Resources