20191305 Ver 1_WRC Comments_20191015

ltl North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
October 15, 2019
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Highlands Retail Development Project
UT to Big Creek, Macon County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to place two culverts on an unnamed tributary (UT) to Big Creek, impacting 131 feet of
stream in Macon 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 Brook Trout are found in the project vicinity and in -stream work should be avoided during the
trout moratorium of October 15 to April 15 to minimize impacts to trout spawning. Due to the
sensitivity of these species to sedimentation, it is extremely important that excellent erosion and
sediment control are used during construction of this site.
The project site is on 2.2 acres of cleared and forested land. The development will involve
permanent disturbance of 0.83 acre (0.72 acre of which is impervious) for retail buildings, parking,
and septic treatment. The plans note that as the project drains to High Quality Waters, ground
stabilization will be achieved within 7 calendar days of the last land disturbing act. Two reinforced
concrete pipe (RCP) culverts are proposed; we recommend against using RCP material, as it is
smooth and is less likely to hold stream substrate and provide for movement of aquatic organisms
like fish and salamanders.
Because the site will drain to High Quality Waters and streams occupied by wild Brook Trout, we are
especially concerned about the potential for impacts from stormwater from the site. We strongly
recommend that the design incorporate on -site stormwater control measures that together mimic a
hydrograph consistent with an impervious coverage of less than 10% and remove stormwater
pollutants. We recommend using Low Impact Development (LID) techniques in site design in order
to lessen the impact of the development on the natural hydrologic cycle by using native vegetation
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Highlands Retail Development Page 2 October 15, 2019
UT Big Cr, Macon County
and natural drainage patterns, optimizing water infiltration, and implementing smaller localized best
management practices. As the site drains to a cool water mountain stream, stormwater management
practices should be designed to release cooler water.
We offer the following recommendations for the project to minimize impacts to fish and wildlife
resources:
1. Be vigilant with sediment and erosion control during site staging, construction, and cleanup. We
ask that disturbed areas be stabilized on a tighter timeframe than that in the regulation to
minimize risk of sediment loss, namely, that the disturbed areas be seeded, mulched and/or
matted as soon as possible, preferably at the end of each work day; at a minimum, disturbed areas
should be stabilized within five working days or seven calendar days, whichever is shorter.
2. Any matting used on site should be free of nylon mesh; nylon mesh netting frequently entangles
wildlife and is slow to degrade, resulting in a hazard that may last for years.
3. We recommend against using RCP culverts, as RCP is smooth and is less likely to hold stream
substrate and provide for movement of aquatic organisms like fish and salamanders.
4. In -stream activities should be avoided between October 15 and April 15 in order to minimize
impacts to Brook Trout spawning.
5. The stream should not be excavated except in the immediate vicinity of the utility and road
crossing locations.
6. Manage stormwater from the site in order to mimic a hydrograph consistent with an impervious
coverage of less than 10%. Incorporate Low Impact Development (LID) techniques in site
design. Ensure that stormwater management controls temperature, releasing cool water
downstream.
7. Use non-invasive native species and LID technology in landscaping. Using native species
instead of ornamentals should reduce the need for water, fertilizers and pesticides. Using LID
technology in landscaping will not only help maintain the predevelopment hydrologic regime, but
also enhance the aesthetic and habitat value of the site.
8. Maintain a minimum of a 30-ft undisturbed, native, forested buffer along all streams and
wetlands on the property. Maintaining undisturbed, forested buffers will minimize impacts to
aquatic and terrestrial wildlife resources, water quality, and aquatic habitat both within and
downstream of the project area. Wide riparian buffers are helpful in maintaining stability of
stream banks and for treatment of pollutants associated with urban stormwater. In addition, these
buffers will provide an adequate travel corridor for wildlife species.
9. We recommend maintaining undeveloped parts of the parcel as forested habitat and conserving
these areas as green space.
Thank you for the opportunity to review and comment on this project. Please contact me at (828)
803-6054 if you have any questions about these comments.
Sincerely,
zo" e J' d-
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Michelle Campbell, ARC Environmental
Andrew Moore and Zan Price, NC Division of Water Resources