20220041 Ver 1_WRC Comments_20220203

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
February 3, 2022

Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: B&F Ceramics
UT to Brandy Branch and wetland, Henderson County

Dear Mr. Brown,

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert 248 ft of an unnamed tributary (UT) to Brandy Branch and fill 0.244 acre
of wetland 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).

The project should not impact trout reproduction, and project activities do not need to be avoided
during the trout spawning moratorium. However, the site is upstream of the Mills River Aquatic
Habitat, a NC Natural Heritage Program natural area rated Very High due to the richness of rare
species it supports. Species in the vicinity of the project include Appalachian Elktoe
[Alasmidonta raveleniana, US Endangered (E), NC E], Slippershell [Alasmidonta viridis, US
Federal Species of Concern (FSC), NC E], Creeper (Strophitus undulatus, NC Threatened),
Eastern Hellbender [Cryptobranchus alleganiensis, US FSC, NC Special Concern (SC)], and
Blotched Chub (Erimystax insignis, NC SR). Excellent sediment and erosion control are
essential to minimize impacts to these important species.

The project involves the development of a 12.5-acre site for commercial development, including
a warehouse, a residential structure, cement pads for future commercial uses, parking, and more.
The proposed culvert would be placed upstream of a culverted section of the same stream. The
wetland would be filled to construct an on-site residential structure. This wetland rated as
Medium via the NC Wetland Assessment Method. The 0.244 acre of impact would be mitigated
at a 2:1 ratio.

B&F Ceramics Page 2 February 3, 2022
UT Brandy Br & wetlands, Henderson Co
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Due the importance of the Mills River, which supports state and federally listed species, it is
extremely important to use excellent erosion and sediment control on site. We request ask that
the applicant use sediment and erosion control practices outlined in the Design Standards in
Sensitive Watersheds (15A NCAC 4B .0124). We ask that disturbed areas be stabilized on a
tight timeframe to minimize risk of sediment loss, namely, the disturbed areas 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.
2. Any erosion control matting used should be free of nylon or plastic mesh, as this type of mesh
netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last
for years.
3. Limit impervious surface to less than 10% or use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10%.
4. Use non-invasive native species and Low Impact Development (LID) technology in
landscaping. Using native 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.
5. Maintain open space areas with native vegetation and maintain the undeveloped area to the
north as a forested green space.

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.

Sincerely,

Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program

ec: Kaylie Yankura, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service
Michelle Savage-Measday, ECS Southeast