20201654 Ver 1_WRC Comments_20210401

4
North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
April 1, 2021
Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Mulberry Gap Farms
Thomas Branch, Hopewell Branch, and UTs, Madison County
Dear Ms. Boggs:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to fill 0.108 acre of wetland, temporarily impact 268 ft (0.67 acres) of unnamed
tributaries (UTs) to Thomas Branch, and permanently impact 1,695 ft of Hopewell Branch, Thomas
Branch, and UTs to Thomas Branch for the development of a residential education center in Madison
County. NCWRC staff visited the site on November 12, 2020 and March 25, 2021. 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 should not impact wild trout and do not need to be avoided during a trout
moratorium.
The project involves the development of a 448-acre site called the School of Wholeness and
Enlightenment. The development entails roads, various residential, instructional, and administrative
buildings, roads, and parking areas. Many of the buildings would border inundated areas created by
beaver dam analogs, or small dams constructed of wood, rock, and soil.
Components of the project include the following:
• Construction of seven beaver dam analog structures, which would impact 1,695 ft of stream and
0.079 acre of wetland through either structure placement or inundation. Most of these impacts
are proposed under a Nationwide Permit (NWP) 27 (aquatic habitat restoration). A subset of
these impacts (46 ft of stream and 0.002 acre of wetland) involve one BDA-created pond that
would be underlain with a clay layer to retain water, and these impacts are proposed under a
NWP 39 (residential development).
• Removal of five culverts on UTs to Thomas Branch.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Hopewell Br, Thomas Br, Madison Co
• Stream enhancement on 268 ft of Thomas Branch.
• Installation of one culvert on Thomas Branch and one culvert on UT to Hopewell Branch,
impacting a total of 40 ft of channel Fill of 0.029 acre of wetland for roads and other
infrastructure.
Beaver dam analogs (BDAs) have been used extensively in the western US to establish better
floodplain connection, raise water table levels, and restore/create riparian habitats, including
wetlands. However, there have been limited attempts to apply BDAs in the eastern US, and few
examples exist in the Southeast. NCWRC recognizes the potential benefits of the creation of a
mosaic of stream, pond, wetland, and upland habitats behind BDA structures. However, we have a
number of concerns with the use of BDAs as designed for the Mulberry Gap Farms project, which
we outline below.
• Although six of seven of the BDA impact areas are proposed through NWP 27 as ecological
restoration, it appears that they will have limited ecological value as designed. Almost all of the
BDAs will be placed downstream of areas that will be excavated to provide deeper pools. The
application notes that at least 50 percent of the inundated areas will be at least 4 ft deep (often 5-8
ft deep). The larger BDA complex on Thomas Branch appears to be more of a step -pool pond
system, with BDAs stretched across the entire floodplain and each BDA set at elevations that will
likely flood the upstream area to the next BDA. The emphasis on deeper water behind the BDAs
will limit the development of wetland areas and the establishment of rooted vegetation. Instead,
open water may dominate much of the impacted area, and perhaps the only vegetation that will
succeed may be on the fringes of the inundated areas.
• It is difficult to understand how deep the water may be behind each BDA. We request that a
series of bathymetric maps be developed that show the depth of water across the landscape at
various levels of inundation. These maps should also indicate the height of the BDA structures.
An alternative would be a set of maps that show the profile of the valley punctuated by each
BDA.
• At a pre -application meeting, agency staff recommended that the applicant develop a robust
monitoring plan to document the changes within the impact areas and to provide a measure of
ecological uplift. The application proposes to measure water temperature and precipitation and
document site changes through photographs. A more robust monitoring plan is needed to
document ecological uplift, including elements such as quantitative/qualitative vegetation
surveys, water depth measurements, stream flows, monitoring well measurements, and wildlife
surveys.
• We recommend establishing success criteria for the project to support the use of NWP 27. These
success criteria could be modeled on mitigation success criteria (e.g., vegetation success,
monitoring well criteria). The monitoring plan should be carefully designed to gauge the degree
to which the site is meeting these criteria. Adaptive management should be required if success
criteria are not met.
• Beaver dams are inherently transient and not fixed to particular locations in the stream network.
We are concerned about the potential for BDA blow-out. The application notes that BDAs will
be inspected after large storms (i.e., 3-inch rain in a 24-hour period) and seasonally. We
recommend quarterly inspections at a minimum, as frequent inspections will be necessary to
ensure BDA stability.
• Due to the concerns about BDA function and stability, we recommend phasing this work by
implementing a BDA design in one place (e.g., Hopewell Branch) to start. This BDA should be
closely monitored for stability and ecological uplift.

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Hopewell Br, Thomas Br, Madison Co
• Although the application states that native vegetation will be planted in the BDA areas, no plant
list is provided. We request a list of herbaceous plants, shrubs, and trees to be planted, as well as
a planting plan, which provides a map of the likely areas to be planted.
• NCWRC does not support the construction of in -line ponds. The BDA associated with the 0.36-
acre pond that will be underlain with a clay liner and fitted with an agri-drain will essentially
function as an in -line pond.
The application proposes 240 ft of stream enhancement on Thomas Branch, and information on the
structures to be used is provided. We ask that a plan view map be provided, noting the location of
various structures and bank stabilization features.
We offer the following additional recommendations to minimize impacts to aquatic and terrestrial
wildlife:
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 near streams should
be seeded, mulched and/or matted as soon as possible, preferably at the end of each work day.
2. In -stream work (including BDA construction) should be done in the dry, with flows pumped
around work areas.
3. Seeding specifications have not been provided. Seeding mixes should not include invasive
species, such as Tall Fescue and Sericea Lespedeza. Permanent seed mixes should be comprised
of native grasses and forbs. We recommend using pollinator -beneficial species, in particular.
4. 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.
5. Effective stormwater management is essential in minimizing impacts to downstream waters. We
recommend the use of Low Impact Design techniques, such as grassed swales and pervious
pavement; curb and gutter, catch basins, and underground piping of stormwater should be
avoided. 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.
Thank you for the opportunity to review and comment on this project. Please contact me at (828)
400-4223 if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Clement Riddle, ClearWater Environmental
Sue Homewood & Andrew Moore, NC Division of Water Resources
Byron Hamstead & Karla Quast, US Fish and Wildlife Service
Chris Goudreau, NCWRC