20220796 Ver 1_WRC Comments_20220705

® North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
July 5, 2022
Ms. Samantha Dailey
U.S. Army Corps of Engineers, Regulatory Branch
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
SUBJECT: White Road Subdivision
UT to Crooked Run Creek, Stokes County
Dear Ms. Dailey:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 219 ft and temporarily impact 40 ft of an unnamed tributary
(UT) to Crooked Run Creek, as well as fill 0.001 acre of wetland, in Stokes 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 trout reproduction should not be impacted by project activities, and a trout moratorium does
not apply.
Impacts are associated a development on 85 acres. Stream impacts are associated with the
installation of two reinforced concrete pipe (RCP) culverts. We recommend against RCP and
high density polyethylene (HDPE) culverts, as these smooth materials are less likely to hold
stream substrate and provide for movement of aquatic organisms like fish and salamanders.
We offer the following recommendations to minimize impacts to fish and wildlife:
I. 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.
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.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

White Road Subdivision Page 2 July 5, 2022
UT to Crooked Run Cr, Stokes Co.
3. The proposed culverts are 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.
4. Effective stormwater management is essential in minimizing impacts to downstream waters.
Stormwater control measures should mimic the hydrograph consistent with an impervious
coverage of less than 10%. We recommend the use of Low Impact Design techniques, such
as grassed swales and pervious pavement; curb and gutter, catch basins, and underground
piping of stormwater should be avoided. As stormwater runoff from pavement can cause
short-term temperature spikes in downstream waters, mechanisms to lower stormwater
temperature should be incorporated into the stormwater management design.
5. Maintain open space areas with native vegetation.
Thank you for the opportunity to review and comment on this project. Please contact meat
[phone] if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Meagan Jolly, Wetlands and Waters, Inc.
Sue Homewood, NC Division of Water Resources