20230877 Ver 1_WRC Comments_20230728

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
July 28, 2023
Ms. Brandee Boggs
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Hot Springs Sewer Improvement
Spring Creek, Madison County
Dear Ms. Boggs:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to temporarily impact 426 ft and permanently impact 62 ft of Spring Creek in
Madison 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, and a trout moratorium is
not needed. However, the Spring Creek is part of the Lower French Broad River Aquatic
Habitat, a NCNHP natural area rated Exceptional due to the richness and importance of rare
species it supports. These species include the Logperch (Percina caprodes, NC Threatened),
Eastern Hellbender [Cryptobranchus alleganiensis, US Federal Species of Concern (FSC), NC
Special Concern (SC)], Freshwater Drum (Aplodinotus grunniens, NC SC), Banded Sculpin
(Cottus carolinae, NC SC), Mountain Madtom (Noturus eleutherus, NC SC), Olive Darter
(Percina squamata, NC SC), Eastern Spiny Softshell (Apalone spinifera, NC SC), Ohio Lamprey
(Icthyomyzon bdellium, NC SC), Mountain Brook Lamprey (Lethenteron appendix, NC SC),
Blotched Chub [Erimystax insignis, NC Significantly Rare (SR)], Highland Shiner (Notropis
micropteryx, NC SR), and French Broad River Crayfish (Cambarus reburrus, NC SR).
Excellent sediment and erosion control are necessary to minimize impacts to this stream and the
rare species it supports.
The application proposes to replace a malfunctioning sewer and manholes along Spring Creek.
Two areas of problematic erosion totaling 62 ft would be stabilized with a block retaining wall.
Another 426 ft of stream would be impacted by installation of a coffer dam (sand bags and
riprap) to isolate the stream from the work for the sewer line installation. Trees would be
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Hot Springs Sewer Improvement Page 2 July 28, 2023
Spring Cr, Madison Co
removed and after the work is completed, banks sloped and stabilized with riprap and native
seed. Work would take approximately 45 days.
Instead of stabilizing the stream banks with riprap and seed, we strongly recommend planting
native shrubs and trees instead. Even a narrow line of woody vegetation can afford wildlife
benefits, bank stabilization, and stream shading.
We offer the following recommendations to minimize impacts to the aquatic community:
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
areas should be stabilized at the end of each work day.
2. Instead of riprap, we recommend stabilizing stream banks with live stakes and containerized
native trees and shrubs.
3. 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.
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: Jonathan Herman, McGill Associates
Andrew Moore, NC Division of Water Resources