20221432 Ver 1_WRC Comments_20221116

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North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
November 16, 2022
Ms. Brooke Davis
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Lantz Development
UT to Mills River, Henderson County
Dear Ms. Davis,
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert 450 ft of an unnamed tributary (UT) to Mills River in Henderson 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).
The project should not impact trout reproduction, and project activities do not need to be avoided
during the trout spawning moratorium. However, the site is upstream of the Mills River Aquatic
Habitat, a NC Natural Heritage Program natural area rated Exceptional due to the richness of rare
species it supports. Species in the vicinity of the project include Appalachian Elktoe
[Alasmidonta raveleniana, US Endangered (E), NC E], Slippershell [Alasmidonta viridis, US
Federal Species of Concern (FSC), NC E], Creeper (Strophitus undulatus, NC Threatened),
Eastern Hellbender [Cryptobranchus alleganiensis, US FSC, NC Special Concern (SC)], and
Blotched Chub (Erimystax insignis, NC SR). Excellent sediment and erosion control are
essential to minimize impacts to these important species.
The project involves the development of a 12.8-acre site for commercial development. The
proposed culvert would be on an intermittent stream. Mitigation for this impact is proposed to
be satisfied from a preservation -only site. We recommend that only 50% of the mitigation be
satisfied through preservation.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Lantz Development Page 2 November 16, 2022
UT Mills River, Henderson Co
We offer the following recommendations to minimize impacts to fish and wildlife resources:
1. Due the importance of the Mills River, which supports state and federally listed species, it is
extremely important to use excellent erosion and sediment control on site. We request ask that
the applicant use sediment and erosion control practices outlined in the Design Standards in
Sensitive Watersheds (15A NCAC 4B .0124). We ask that disturbed areas be stabilized on a
tight timeframe to minimize risk of sediment loss, namely, the disturbed areas be seeded,
mulched and/or matted as soon as possible, preferably at the end of each work day; at a
minimum, disturbed areas should be stabilized within five working days or seven calendar
days, whichever is shorter.
2. Any erosion control matting used should be free of nylon or plastic mesh, as this type of mesh
netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that may last
for years.
3. Minimize stream impacts by shifting the developed area away from streams.
4. Maintain open space areas with native vegetation and maintain the undeveloped area 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: Andrew Moore, NC Division of Water Resources
Adam Tripp, Headwater Environmental