20200121 Ver 1_WRC Response Letter_20200226

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February 26, 2020
Ms. Andrea Leslie
Mountain Habitat Conservation Coordinator
NC Wildlife Resources Commission
645 Fish Hatchery Road, Building B
Marion, North Carolina 28752
RE: Moose Branch Subdivision Project
UT to Mauney Branch
Graham County, North Carolina
Dear Ms. Leslie:
Thank you for your comments regarding the Pre -construction Notification we submitted for
the Moose Branch Subdivision Project. Please find a response to your comments below:
1. Work should be accomplished as quickly as possible and vigilance used in sediment and
erosion control during site preparation, construction, and clean up.
Understood. Work will be accomplished in a timely manner and in accordance
with all applicable erosion and sediment control standards.
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.
Biodegradable matting has been specified for stabilization of the steep slopes,
however, the steepness and resulting erosive velocities that some of the drainage
diversions will experience dictates the use of more durable, permanent matting to
prevent soil erosion in those locations.
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.
While we understand your concerns regarding RCP pipes, we would prefer to stick
with a standard culvert type accepted by the NC Department of Transportation who
will eventually be responsible for maintenance of the road and culvert. To promote
movement of aquatic organisms the plans call for countersinking the culverts four
inches into the streambed. The countersinking should help stream substrate to
accumulate and stabilize within the pipe. Additionally, the plans have been revised
to show removal of an existing driveway pipe and restoration of approximately 20
linear feet of `UT to Mauney Creek'. This activity should also help with the efforts
to promote movement of aquatic organisms.
4. We recommend replacing the double culverts with a spanning structure such as a bridge
or bottomless arch instead. If a culvert must be used, we recommend using a single
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Ms. Andrea Leslie, NCWRC
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larger squash pipe capable of carrying base and stormflows.
A 44" x 27" Arch RCP pipe is now proposed instead of the dual 24" RCPs. The
culvert alignment has also been modified to fit the road right-of-way and
downstream stream location to minimize potential downstream erosion.
5. If at all possible, remove the culvert and restore the wetland impacts associated with
construction access.
The stream crossing labeled as `Shared Drive 1' on sheet C-101 is proposed as a
permanent road needed to access Lots 4, 5, and 6. As such, removal of the culvert
and restoration of all wetland impacts in this area are not possible. Wetlands that
are temporarily impacted during construction will be restored.
6. Tall Fescue is listed as a temporary and permanent seed; this species is highly invasive
and should be avoided.
Tall fescue is not part of the seed mix provided for stream bank and wetland
stabilization. Use of tall fescue is listed as an acceptable practice for establishing
primary stabilization in the NCDEQ Erosion and Sediment Control Planning and
Design Manual. Due to its wide range of acceptable planting times, hardiness, and
ability to be maintained and mowed, we would prefer to allow the use of tall fescue
as a means of establishing site stabilization in other areas. As this project involves
development of the property into residential lots, the associated lawn areas will
also likely contain fescue -type turf.
7. In -stream activities should be avoided between January 1 and April 15 in order to
minimize impacts to Rainbow Trout spawning.
A note will be added to the plans that in -stream activities should be avoided
between January 1 and April 15.
8. The stream should not be excavated except in the immediate vicinity of the utility and
road crossing locations.
Excavation in the stream channel is only proposed within the limits of disturbance
which is only in the immediate vicinity of the utility and road crossings.
9. 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.
Various strategies to minimize impervious cover and promote infiltration were
incorporated into the design including vegetated swales, no curb and gutter,
minimum street pavement widths, and minimal piping of drainage.
Recommendations regarding stormwater management and the incorporation of
LID techniques in future site design will be passed along to the landowner for
consideration.
10. Use non-invasive native species and LID technology in landscaping. Using native
MCGILL ASSOCIATES 1013 STATE FARM ROAD, BOONE, NC 28607 / 828.386.1920 / MCGILLASSOCIATES.COM

Ms. Andrea Leslie, NCWRC
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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.
Landscaping is outside the scope of work of McGill's contract, however, these
landscaping recommendations will be passed along to the landowner.
11. We recommend maintaining undeveloped parts of the parcel as forested habitat and
conserving these areas as green space.
This recommendation will be passing along to the landowner for consideration.
Thank you for your review and guidance on this project. We feel the revisions as described
in the responses above adequately address your concerns regarding the project. If you have
any additional comments or there are other issues of significance that may affect this project
let us know. Feel free to contact me at our office phone number of [phone] or my
email address jon.swaim(@Mcgillassociates.com.
Sincerely,
MCGILL ASSOCIATES, PA
JON SWAIM
Project Manager / Environmental Services
MCGILL ASSOCIATES 1013 STATE FARM ROAD, BOONE, NC 28607 / 828.386.1920 / MCGILLASSOCIATES.COM