20220142 Ver 1_WRC Comments_20220215

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North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
February 15, 2022
Ms. Crystal Amschler
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Busbee Phase 1 and la
Four Mile Branch, unnamed tributary, and wetlands, Buncombe County
Dear Ms. Amschler:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently culvert 122 ft of Four Mile Branch and an unnamed tributary (UT)
and fill 0.066 acre of wetland in Buncombe County. Additionally, 40 ft of temporary stream
impacts and 0.02 acre of temporary wetland impact are proposed. 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 project activities.
HDPE culverts are proposed on the two stream crossings. We recommend against HDPE, as this
smooth material is less likely to hold stream substrate and provide for movement of aquatic
organisms like fish and salamanders. In addition, one of the culverts is sited on a significant
meander bend; we recommend moving the road so that the crossing is on a straight section of
stream.
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]

Busbee Phase 1 and la Page 2 February 15, 2022
Four Mile Br, UT, and wetlands, 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. The proposed culvert would be HDPE 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.
4. Reroute the road so that a shorter and straighter crossing can be constructed on the UT to
Four Mile Branch.
5. We recommend maintaining a buffer of at least 30 ft on the streams to provide shade and
ensure streambank stability.
6. Temporary impacts to wetlands should be minimized by placing heavy equipment on mud
mats and reseeding wetlands with native wetland seed. Non -impacted wetlands should be
fenced off so that equipment is not placed within them.
7. 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%.
8. 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.
9. 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: Jeff Golladay, Clearwater Environmental
Andrew Moore, NC Division of Water Resources