20221490 Ver 1_WRC Comments_20230106

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North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
January 6, 2023
Ms. Brooke Davis
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Phase I Door of Hope Campus
Wheat Creek and UT, Polk County
Dear Ms. Davis:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 149 ft of Wheat Creek and an unnamed tributary (UT), and
temporarily impact 80 ft Wheat Creek and UTs for a development in Polk 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. However, two Significantly
Rare species are found in the vicinity of the project — the Seagreen Darter (Etheostoma
thalassinum) and Carolina Foothills Crayfish (Cambarus johni). To minimize impacts to these
species, effective erosion and sediment control are needed on the project.
The application proposes impacts associated with the development of a religious campus and
involves the installation of a culvert, a double arched span structure, bank stabilization, and
removal of 2 culverts and 1 ford. The double arched span structure would involve the
installation of a footer in Wheat Creek, which is proposed to be done within a coffer dam. It is
extremely important for any concrete pouring and complete curing to be done within a dry area,
with no contact with the stream. Therefore, we recommend pumping the stream around the area
if at all possible.
We offer the following recommendations to minimize impacts to fish and wildlife:
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
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Phase I Door of Hope Campus Page 2 January 6, 2023
Wheat Cr & UTs, Polk Co.
areas should be seeded, mulched and/or matted as soon as possible, preferably at the end of
each work day.
2. Stream bank stabilization should incorporate planting native shrubs and trees, at least through
live staking.
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 double arched span footer must be constructed and cured constructed away from water to
avoid toxic pH levels in contact water.
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: Joel Lenk, Quible and Associates
Andrew Moore, NC Division of Water Resources