20211518 Ver 1_Staff Report Annino, Amy M_20211029

® North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
October 26, 2021
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Richland Estates Townhomes
UT Richland Creek, Haywood County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert 171 ft of an unnamed tributary (UT) to Richland Creek in Haywood
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 trout reproduction should not be impacted by the project, and a trout moratorium is not
needed.
The culvert is proposed to accommodate the construction of townhomes development, part of
which would be in the 100-year floodplain. The NCWRC does not support commercial or
residential development within the 100-year floodplain. The filling of floodplains increases the
potential for flooding and degrades in -stream habitats for fish and other aquatic organisms.
We offer the following recommendations to minimize impacts to fish and wildlife:
I. In -channel 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 should be seeded, mulched and/or matted as soon as possible, preferably at the end of
each workday.
2. Any erosion control matting used should be free of plastic or nylon mesh, as this type of
mesh frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last
for years.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Richland Estates Townhomes Page 2 October 26, 2021
UT Richland Creek, Haywood Co.
3. The proposed culvert would be HDPE material. We recommend against using HDPE or
reinforced concrete material, as this material is less likely to hold stream substrate and
provide for movement of aquatic organisms like fish and salamanders.
Thank you for the opportunity to review and comment on this project. Please contact meat
[phone] if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Daniel Hyatt, Wade Trim
Amy Annino, NC Division of Water Resources