20210403 Ver 1_WRC Comments_20220119

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North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
January 19, 2022
Ms. Crystal Amschler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Brooks Cove Road
UT to Swannanoa River and wetlands, Buncombe County
Dear Ms. Amschler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert 177 ft of an unnamed tributary (UT) to the Swannanoa River and fill 0.053
acre of wetland in Buncombe 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 Rainbow Trout are found downstream of the project, and instream activities should be
avoided between January 1 and April 15 to minimize impacts to trout reproduction. In addition,
Eastern Hellbender (Cryptobranchus alleganiensis, US Federal Species of Concern, NC Special
Concern) is found in the Swannanoa River. Excellent erosion and sediment control are necessary
to minimize impacts to these sensitive species.
Reinforced concrete pipe (RCP) culverts are proposed on two stream crossings. We recommend
against RCP, as this smooth material is less likely to hold stream substrate and provide for
movement of aquatic organisms like fish and salamanders. We recommend maintaining a buffer
of at least 30 ft on the stream to provide shade and ensure streambank stability.
We offer the following recommendations to minimize impacts to fish and wildlife:
1. 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 work day. A native riparian seed mix and native shrubs and trees should be used to
permanently stabilize disturbed stream areas.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Brooks Cove Road Page 2 January 19, 2022
UT Swannanoa R, Buncombe Co.
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.
3. In -stream activities should be avoided between January 1 and April 15 in order to minimize
impacts to wild trout reproduction.
4. The proposed culvert would be RCP material. We recommend against using RCP or HDPE
material, as this material is less likely to hold stream substrate and provide for movement of
aquatic organisms like fish and salamanders.
5. We recommend maintaining a buffer of at least 30 ft on the stream to provide shade and
ensure streambank stability.
6. 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%.
7. 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.
8. Limit native vegetation clearing as much as possible. 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: Britten Yant, Clearwater Environmental
Andrew Moore, NC Division of Water Resources