20211837 Ver 1_WRC Comments_20220216

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North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
February 16, 2022
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: The Cottages at Roper Road
UTs to Boylston Creek and wetland, Henderson County
Dear Mr. Brown,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert 299 ft of unnamed tributaries (UTs) to Boylston Creek and fill 0.009 acre
of wetland in Henderson County. Additional temporary impacts include 140 ft of UTs to
Boylston Creek. 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).
There are Rainbow Trout in the project vicinity and in -channel activities should be avoided
between January 1 and April 15 to minimize impacts to trout spawning.
The project involves the development of a 32-acre site for residential development of 32 houses.
Seven culverts would be installed, including 2 double-barreled RCP culverts and 5 HDPE
culverts. We recommend against using HDPE and RCP material, as this material is less likely to
hold stream substrate and provide for movement of aquatic organisms like fish and salamanders.
In addition, 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 replacing the double culverts with a spanning structure such as a bridge
or bottomless arch instead. If a culvert must be used, we recommend using a single larger squash
pipe capable of carrying base and stormflows.
We offer the following recommendations to minimize impacts to fish and wildlife resources:
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
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

The Cottages at Roper Rd Page 2 February 16, 2022
UTs Boylston Cr & wetland, Henderson Co
each work day. A native riparian seed mix and native shrubs and trees should be used to
permanently stabilize disturbed stream areas.
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. 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.
In addition, we recommend replacing the double culverts with a spanning structure such as a
bridge or bottomless arch instead. If a culvert must be used, we recommend using a single
larger squash pipe capable of carrying base and stormflows.
5. We recommend establishing and maintaining a buffer of at least 30 ft on the streams 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.
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: Mitchell Anderson, NC Division of Water Resources
Jennifer Robertson, Atlas Environmental