20201654 Ver 3_WRC Comments_20230621

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
June 21, 2023
Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Thomas Branch, Hopewell Branch, and UTs, Madison County
Dear Ms. Boggs:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to modify the 401/404 permit for Mulberry Gap Farms in Madison County. NCWRC
has been to the site several times and has commented on past designs and permit applications.
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).
Project activities should not impact wild trout and do not need to be avoided during a trout
moratorium.
The project involves the development of a 448-acre site called the School of Wholeness and
Enlightenment. The permit modification greatly lessens wetland and stream impacts, eliminating
beaver dam analogs on Thomas Branch and Hopewell Branch and some culvert impacts. Total
proposed impacts are now 1,754 ft of stream restoration, 100 ft of culverts, and 0.06 acre of
wetland fill. Impacts are now below the mitigation threshold.
The stream restoration plan involves stream relocation, rock sills, stone toe, constructed riffles,
and native riparian planting. We note that an excellent planting list has been developed, but
buffer widths range in width, some only 5 ft. We strongly recommend expanding buffer widths to
at least 30 ft as infrastructure allows in order to ensure project success. A wide forested buffer
can ensure greater bank stability, filter overland pollutants, and provide habitat for birds and
other wildlife.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Mulberry Gap Farms — Permit Modification Page 2 June 21, 2023
Thomas Br, Hopewell Br, Madison Co
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
cc: Clement Riddle, C1earWater Environmental
Sue Homewood & Andrew Moore, NC Division of Water Resources