20150392 Ver 1_WRC Comments_20150515

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
May 14, 2015
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801 -5006
SUBJECT: Comments on Mill Pond Sewer Line
Mill Pond Creek and tributaries and UTs to French Broad River, Henderson
County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to install 5.2 miles of sewer line, crossing fifteen streams and one wetland via trench
cut method. 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 will impact 300 feet of stream on Mill Pond Creek, unnamed tributaries (UTs) to
Mill Pond Creek, and UTs to the French Broad River, as well as 0.01 acre of wetland. This work
should not affect trout and construction does not need to be avoided during the trout moratorium
period.
The proposed sewer line crossings will be installed via trench cut method. The stream bank
stabilization and crossing detail provided in the application specifies rip rap and filter fabric
along on the stream bank from the typical high water depth to at least 6 in below the stream bed.
Rip rap is to be placed within the stream bed and +/- 6 in of natural stream substrate is to be
placed on top of this. The channel dimensions would be altered, and a berm would be
constructed.
We have the following recommendations:
1. The use of rip rap on the stream bank should be avoided if at all possible. We recommend
stabilizing the banks with native woody vegetation instead.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699 -1721
Telephone: [phone] • Fax: [phone]

Mill Pond Sewer Line Page 2 May 14, 2015
Mill Pond Cr & UTs, UTs to French Broad R,
Henderson County
2. Stream channels at utility crossings should be restored to near pre - disturbance conditions.
Channel dimensions should mimic the existing dimensions, and the stream bed should set be
at the pre- existing elevation.
3. Effective erosion controls should be used to minimize losses of sediment downstream. Coir
matting over seed and straw should be used on stream banks that have erodible soil. Matting
used for bank stabilization should be free of nylon mesh; nylon mesh netting frequently
entangles wildlife and is slow to degrade resulting in a hazard that may last for years.
4. Avoid the use of Tall Fescue. We recommend a temporary seed mix of an annual grain such
as Rye or Oats, Red Clover, and Creeping Red Fescue.
Thank you for the opportunity to review and comment on this project. Please contact me at
(828) 400 -4223 if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator
Habitat Conservation Program
ec: Clement Riddle, C1earWater Environmental
Zan Price, NC Division of Water Resources