20220461 Ver 1_WRC Comments_20220418

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
April 18, 2022
Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
SUBJECT: 2019 Stormwater Drainage and Sidewalk Improvements
UT to Ararat River, Surry County
Dear Ms. Boggs:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to temporarily impact 97 ft of an unnamed tributary (UT) to the Ararat River 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 replacing a corrugated metal culvert (CMP) with a
reinforced concrete pipe (RCP). Stream banks would be stabilized with riprap. Work would be
performed in the dry.
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
each work day.
2. 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.
3. The application proposes using a RCP culvert. 48 inch smooth -walled HDPE culvert. We
recommend against using RCP or high density polyethylene culvert material, as this smooth
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Sto'water Drainage & Sidewalk Improvements Page 2 March 18, 2022
UT Ararat R, Surry Co
material is less likely to hold stream substrate and provide for movement of aquatic
organisms like fish and salamanders.
4. Instead of using riprap to stabilize the banks, we recommend bank sloping and 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: Kevin Heath, The Lane Group
Sue Homewood, NC Division of Water Resources