20220228 Ver 1_WRC Comments_20220228

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
February 28, 2022
Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Blessing Drive Stormwater Utility Improvements
Cody Creek, Surry County
Dear Ms. Boggs:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to temporarily impact 35 ft and permanently impact 53 ft of Cody Creek in Surry
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).
Project activities will not impact wild trout, and project activities do not need to be avoided
during a trout moratorium.
The application describes impacts involved in installing a water and sewer line via trench cut and
replacing a failing culvert with a set of two 42-inch reinforced concrete pipe (RCP) culverts.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Sediment and erosion controls measures should be installed prior to any land clearing or
construction. These measures should be routinely inspected and properly maintained.
Excessive silt and sediment loads can have numerous detrimental effects on aquatic resources
including destruction of spawning habitat, suffocation of eggs, and clogging of gills of
aquatic species.
2. For the trench cuts, the top 6-12 inches of stream substrate should be stockpiled, kept
saturated during pipe installation, and replaced once the pipe is installed.
3. We recommend against using side -by -side culverts set at the same elevation. Double
culverts set at the same elevation often result in one culvert carrying most or all of the flows
over time; this can cause channel instability and problems with aquatic organism passage.
We recommend using a single larger squash pipe capable of carrying base and stormflows. If
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Blessing Dr Sto'water Utilty Page 2 February 28, 2022
Cody Creek, Surry Co
double culverts must be used, one should be set at a higher elevation (or upstream and
downstream sills used) so that it carries stormflows only. In addition, we recommend against
using RCP material, as this smooth material is less likely to hold stream substrate and
provide for movement of aquatic organisms like fish and salamanders.
4. Matting used for stabilization should be free of nylon or plastic mesh, as this type of netting
frequently entangles wildlife and is slow to degrade resulting in a hazard that may last for
years.
5. We recommend the use of a native perennial seed mix and livestakes on disturbed
streambanks.
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: Laura Neely, Town of Dobson
Sue Homewood, NC Division of Water Resources