20201654 Ver 1_WRC Comments_20210901

Strickland, Bev
From: Leslie, Andrea J
Sent: Wednesday, September 1, 2021 11:37 AM
To: Clement Riddle
Cc: Brandee Boggs ([e-mail]); Homewood, Sue; Moore, Andrew
W; Hamstead, Byron A; Cox, David R.; Wilson, Travis W.
Subject: Mulberry Gap Farms - response to NCWRC comments
Follow Up Flag: Follow up
Flag Status: Flagged
Hi Clement-
NCWRC has reviewed the document that responds to NCWRC's comments on the Mulberry Gap Farms
project. As requested, I'm providing a summary of our comments/recommendations on what was presented
in that response:
• There is not a clear difference between pool habitat and deep marsh, as described. Pool habitat would
be >=3 ft in depth and deep marsh would be 2-5 ft in depth. These definitions overlap.
• What is the maximum depth of the deep pool zone?
• The plant list needs to be modified:
o Deep marsh is also defined as supporting submergent plants. Given the range of depths for this
zone, we are wondering what native plants would thrive here. The list provided on plan sheet
L-2.00 for that zone is a list of species that would survive in standing water for a long period but
in inches, not feet of water.
o Shallow marsh is defined as 0-2 ft in depth and supporting submergent plants. Again there are
problems with the plant list provided on L-2.00. These plants cannot survive if inundated for
more than several days. It's a nice list, but it would do best on the fringes of the area that would
see inundation.
o There are no aquatic plants included (although Nymphea odorata is included as an alternate on L-
2.00). Given the depths expected, this suite of plants should be included in the planting list.
o L-2.00 has a note that "alternative and similar native plant species" may be used. We
recommend that this plant list be hammered out with review by agencies. If substitutions are
needed after the fact, they should be vetted with agencies.
• Given the depths of water that are proposed, we are concerned about the risk of invasion of non-native
invasive plants and animals in the BDA impoundments. These may come in with nursery stock (which
is common when planting aquatic plants sourced from nurseries that have issues with non-native
invasives, such as exotic snails, mosquito fish, etc.) or in other ways. The maintenance/monitoring
plan should include surveys for and removal of non -natives.
• We recommend including some sort of time -frame for the vegetation monitoring.
• It is clear that there will be extensive grading done for TB4A. Can you describe the extent of grading to
be done for other BDA features?
Andrea
Andrea Leslie
Mountain Habitat Conservation Coordinator
I.

NC Wildlife Resources Commission
645 Fish Hatchery Rd., Building B
Marion, NC 28752
828-400-4223 (cell)
www.ncwildlife.org
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