20220861 Ver 1_Staff Report Annino, Amy M_20220705

® North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
July 14, 2022
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Crabtree Mountain Road Campground
UTs to Thickety Creek and wetlands, Haywood County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to account for after -the -fact impacts associated with culvert placement and road
widening to 364 ft of unnamed tributaries (UTs) to Thickety Creek and 0.036 acre of wetlands in
Haywood County. I visited the site on July 14, 2022. 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 is
not needed.
Road widening and associated culvert replacement and new installation have taken place on the
site. All culverts are high density polyethylene (HDPE) material. 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, it provides little roughness and
increases the energy of the outflows, increasing the likelihood of downstream erosion.
All of the culverted streams are very small and on steep slopes. As the culverts are already
installed and reinstallation will result in additional disturbance, we instead recommend two
things — stabilizing the development site and stabilizing the downstream stream reaches to
minimize the risk of stream bed/bank erosion. We offer the following recommendations to
minimize impacts to fish and wildlife:
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Crabtree Mtn Rd Campground Page 2 July 14, 2022
UTs Thickety Cr, Haywood Co.
1. Channel reaches downstream of installed culverts should be stabilized as needed with large
rock to ensure that the channel does not erode with high flows. Perched culverts should be
retrofitted with rock to eliminate perch.
2. 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 riparian areas.
3. 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.
4. The site is currently being stabilized, and there is a good cover of temporary seed. To better
stabilize disturbed upland areas, a permanent seed mix should be installed this fall. We
recommend incorporating red clover into the permanent fescue -based seed mix. If possible,
we also recommend adding a few native species to increase habitat benefits, such as
Lanced -leaved Coreopsis Coreopsis lanceolata height 8" to 3'
Deertongue Dicanthelium (Panicum) clandestinum `Tioga' height 1 to 3'
Black Eyed Susan Rudbeckia hirta height 1 to 3'
Showy Partridge Pea Chamaecrista (Cassia) fasiculata height 2 to 3'
Showy Tickseed Bidens aristosa — height 3 to 4'
Switchgrass Panicum virgatum Blackwell', `Cave -in -Rock', `Kanlow' —height 4 to 6'
Big Bluestein Andropogon gerardii height 4 to 6'
5. Numerous areas with steep slopes are eroding, demonstrating rilling. These areas should be
monitored and stabilized as needed.
6. Erosion and sediment control measures, such as straw bales and silt fence, should be
monitored and repaired. We noted numerous areas where these measures had been
overwhelmed by recent flows and sediment lost downslope.
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: Tyson Kurtz, Clearwater Environmental
Amy Annino, NC Division of Water Resources
John Caldwell, Caldwell Trucking & Excavating