20200528 Ver 1_WRC Comments_20200430

❑ North Carolina Wildlife Resources Commission ❑
Gordon Myers, Executive Director
April 30, 2020
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: M228 Exposure Repair
UT to French Broad River, Henderson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to fill 0.08 acre of wetland and culvert 78 ft of an unnamed tributary (UT) to the
French Broad River 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).
This project should not affect trout and the activities do not need to be avoided during the trout
spawning moratorium. However, the project is just upstream of the French Broad River, which
supports Appalachian Elktoe [Alasmidonta raveneliana, US Endangered (E), NC E]. As this
species is sensitive to excess sedimentation, it is especially important to use excellent erosion
and sediment control on site to minimize impacts to this species.
The project would replace a length of gas line that was exposed by a seep that developed in
association with broken buried drain tiles that formerly routed the seep. Wetland soils in the area
would be removed and replaced with fill, and the seep would be culverted and stepped down
with hard structures to a stream.
We offer the following recommendations to minimize impacts to the aquatic community:
1. Be vigilant with sediment and erosion control during site staging, construction, and cleanup.
Due to the presence of Appalachian Elktoe, disturbed areas should 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.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

M228 Exposure Repair Page 2 April 30, 2020
UT French Broad R, Henderson County
2. Wetland disturbance should be kept to a minimum, and we recommend fencing off wetlands
that will not be impacted.
3. Any erosion control matting used should be free of nylon or plastic mesh, as this 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 or need further assistance.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Joey Lawler, S&ME
Andrew Moore, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service