MitchellCountySchools_UTsCranberryCr_Mitchell_NCWRCComments

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
April 26, 2022

Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006

SUBJECT: Mitchell County Schools
UTs to Cranberry Creek, Mitchell County

Dear Ms. Boggs:

Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to culvert 88 ft of unnamed tributaries (UTs) to Cranberry Creek and fill 0.098 acre
of wetland in Mitchell 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 Rainbow Trout and Brown Trout are found in the project vicinity, and in-stream activities
should be avoided between October 15 and April 15 to minimize impacts to trout reproduction.

Stream impacts are associated the construction of a school on 14 acres. High density
polyethylene (HDPE) culverts are proposed for the two stream impacts. 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.

We offer the following recommendations to minimize impacts to fish and wildlife:
1. In-channel work should be avoided between October 15 and April 15 to minimize impacts to
trout reproduction.
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 stream areas.
Mitchell County Schools Page 2 April 26, 2022
UTs Cranberry Cr, Mitchell Co.
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 proposed culverts are HDPE material. We recommend against using reinforced concrete
pipe or HDPE material, as this material is less likely to hold stream substrate and provide for
movement of aquatic organisms like fish and salamanders.
5. Non-impact wetlands should be clearly demarcated and fenced so that heavy machinery does
not access these areas.
6. Limit impervious surface to less than 10% or use stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10%.
7. Use non-invasive native species and Low Impact Development (LID) technology in
landscaping. Using native species instead of ornamentals should reduce the need for water,
fertilizers and pesticides. Using LID technology in landscaping will not only help maintain
the predevelopment hydrologic regime, but also enhance the aesthetic and habitat value of
the site.

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: Eric Romaniszyn
Mitchell Anderson, NC Division of Water Resources